ML20202E715
| 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) | |
See also: IR 05000219/1986009
Text
{{#Wiki_filter:__ _ _ _ . 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 Oyster Creek Nuclear Generating Station i 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. - 1., l Approved by: ' 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.
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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
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- 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 ! l 4 b -- . ... . . . .
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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 lf Oyster Creek and to assist in responding to questions posed by ' the NRC staff. These engineering activities formed an integral j 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.
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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 ' l lack of documentation the inspectors were not able to verify ' 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 ) l ! i-. .---- _ - - . - - , . , . _ - , - - - _ - - . _ . - - - - - . -
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) 5 ' ! . 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. i , I l - i ! ! 4 - - - . . - - - - . - - - - - - - - - - - - - - -
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' . j 6 ' ! - i 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) ! i l 1
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. ' 7 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. _ - .. - - _ _
- - - . _ _ __ . - . 4 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
60 day response . '
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 , ! ! i , _ _ _ - _ _ _ _ _ _ _ _ , - - --. + - - -- ---e ,
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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 Wall Drawing Number Status , l 2 1 9 Preemptive 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 ' 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. 2 Walls shown in groups were analyzed in one combined model. - ! 3 - All drawing numbers beginning with 0370 indicate Impell Corp. drawings. 4 N/A = Not Applicable. - 4
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