ML20214J528

Responds to NRC Re Violations Noted in Insp Rept 50-219/86-09.Corrective Actions:Procedural Controls Established to Ensure Vendor Qualification for Performing Nuclear safety-related Work Per IE Bulletin 80-11

ML20214J528
Person / Time
Site:	Oyster Creek
Issue date:	08/06/1986
From:	Wilson R GENERAL PUBLIC UTILITIES CORP.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
3818F, 5000-86-0975, 5000-86-975, IEB-80-11, NUDOCS 8608150051
Download: ML20214J528 (4)

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. i GPU Nuclear Ma H BW n Iu r 100 interpace earkway Parsippany. New Jersey 07054

> 201 263-6500 TELEX 136-482 August 6, 1986 Writer's Direct Dial Number:

5000-86-0975 Mr. Stewart D. Ebneter, Director Division of Reactor Safety Region I U.S. Puclear Regulatory Conunission i 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection 86-09 re: Bulletin 80-11 Pursuant to 10CFR2.201, the attachment to this letter contains our response to the Notice of Yiolation in Appendix A and the Notice of Deviation in Appendix B of your letter dated June 30, 1986. On July 14, 1986, a response time extension request to 30 days from 20 days was granted by Mr. J. T. Wiggins, Region I, via telephone. Again on July 29, 1986, additional response time was requested to August 6,1986 whict was granted by Mr. J. P. Durr, Region I.

The additional time was needed due to a delay in receipt of your letter and to allow for the final preparation and management review of our response.

Should you have any questions concerning infonnation in the attachment, please contact Mr. Paul F. Czaya at (201) 299-2542.

Y yt ly yours, U606130031 860806 -

@ ! e DR ADOCK 0500 9 , p, j j ;b Vice Pres 4 dent i Technical Functions j RFW/PC/pa cc: ' Dr?Thoma s ' E ? Mu rl ey , a Admi n i s tra to r Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA. 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N.J . 08731 J. Donohew U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Phillips Building, Mail Stop 314 Bethesda, Maryland 20014 GPU Nuclear is a part of the General Public Uti? es System Ik Sq O\

ATTACHMENT Violation 1 10 CFR 50, Appendix B, Criterion VII requires that the purchase of materials, equipment or services be procedurally controlled and documentary evidence be maintained to assure source evaluation, evidence of quality furnished,  !

inspection at the contractor and examination of product upon delivery. The GPUN Operational Quality Assurance Plan, Section 5.1.1.1 also requires evaluation of procurement sources, monitoring of consultants, vendors and contractors and confirmation that purchased items and services meet procurement documents.

Contrary to the above, on May 9,1986, documentary evidence was not available to demonstrate that source evaluation or oversight of quality furnished or delivered was made for Computech Engineering Services, Inc. insofar as this organization's involvement in IE Bulletin 80-11.

This is a Severity Level V violation. (Supplement I)

Response

GPU Nuclear concurs with the above violation, as stated. In 1980, Computech Engineering Services, Inc. was contracted to provide design criteria for revaluating masonry walls at Oyster Creek based upon the state-of-the-art at that time utilizing the generic methodology Computech developed in conjunction with the NSSS Owner's Groups. Quality Assurance requirements were not imposed.

In order to ensure that the criteria remain valid and represent a quality effort, an in-house verification, performed subsequent to the inspection, was recently completed in accordance with Technical Functions Procedure EP-009

" Design Verification". No unacceptable findings resulted. Documentation of the verification has been entered into the document control system.

Subsequent to the initial effort in response to Bulletin 80-11, well defined procedural controls have been established to ensure vendor qualification for performing nuclear safety-related work. GPU Nuclear Procedure TAP-11

" Purchase Requisitions" provides adequate guidance for the procurement of vendor items and services.

Regarding vendor-provided items and services during the Bulletin 80-11 effort, we believe this is an isolated instance. Full compliance has been achieved.

Violation 2 Criterion XVII, Appendix B,10 CFR 50 requires sufficient records shall be maintained to furnish evidence of activities affecting quelf ty, and records shall be identifiable and retrievable. GPLN's Quality Assurance Program Section 3.3 requires that quality assurance records for items and activities covered under the scope of the GPUN QA Program, and records generated by contractors shall be controlled, accepted, retained and retrievable.

3818f

Contrary to the above, on May 9,1986, records which would verify that the licensee's initial masonry wall survey conducted in response to IE Bulletin 80-11, was performed using controlled procedures and/or instructions were either not retained or were not retrievable through the doctment control system.

This is a Severity Level IV violation. (Supplement 1)

Response

GPU Nuclear concurs with the above violation, as stated. Although a masonry wall survey was originally performed, documentation could not be located.

Currently, GPU Nuclear is in the process of reverifying masonry walls at Oyster Creek which have the potential for having nuclear safety-related (NSR) equipment either attached or in their immediate vicinity. The reverification program includes a review of structural and architectural drawings and walkdowns. As part of the walkdown, a data sheet is used to document components attached to or in the immediate vicinity of masonry walls. In certain circumstances, photographs of the walls are taken. The components are then identified to determine if they are NSR or impact NSR equipment.

Reverification documentation is to be entered into the document control system.

To date, approximately 125 masonry walls of the 265 known walls have been walked down. $1nce 48 masonry walls have been previously documer.ted as NSR, 92 walls remain to be walked down. Of the 125 walls walked down during the current refueling outage, one additional wall has been identified as impacting NSR components. A preliminary evaluation indicates these components were installed during the current Appendix R modifications. This evaluation is continuing.

Those walls which are accessible during the current refueling outage, but not during power operation, are being walked down. The remaining walls are scheduled to be walked down in the fall and winter of 1986. Assessment of the walkdown results is scheduled for March 30, 1987 completion.

Should additional masonry walls not currently considered NSR be identified as having NSR components attached or in their immediate vicinity, the walls will be entered into the action plan as was done for the 48 walls already documented as NSR. This will include a structural integrity analysis and, if deficiencies are found, a wall failure consequence analysis.

Deviation w

IE Bulletin 80-11, Masonry Wall Design, dated May 8,1986, informed licensees that existing test data or consei vative assumptions could be used to justify the reevaluation criteria to be applied to existing safety-related walls.

In letters dated November 14, 1980, the licensee responded to Bulletin 80-11 and indicated its commitment to complete the actions delineated in the Bulletin.

3818f

a Contrary to the above, the licensee solely relied upon mortar properties found in the construction specification to detemine the strength value for type M mortar. No documentation was provided which verified that type M mortar was actually used to construct the walls, no test program was undertaken to quantify the mortar strength, nor were conservative assumptions used for the reevaluation criteria.

Response

GPU Nuclear concurs with the above deviation, as stated. Documentation of as-built mortar type and strength could not be located.

A test program has been initiated to determine mortar type. Due to the difficulty in obtaining samples for a compressive strength test, it has been decided to utilize a combination of a petrographic test and chemical analysis. To date, only two testing laboratories have been found which are both capable and willing to perfom these tests. Mortar samples have been collected from one masonry wall. Mditional mortar samples will be obtained prior to restart from the current (Cycle 11R) refueling outage. Preliminary test results are expected prior to restart. Complete documentation with respect to confimation of mortar type is planned to be available by December, 1986.

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3818f

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