IR 05000029/1987001

Insp Rept 50-029/87-01 on 870127-30.Violations noted:1980 Walkdown/Survey of Block Walls Conducted W/O Utilizing Documented & Controlled Procedures

ML20205F902
Person / Time
Site:	Yankee Rowe
Issue date:	03/20/1987
From:	Strodnider J, Varela A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205F836	List: IR 05000029/1987001 ML20205F832 ML20205F874
References
50-029-87-01, 50-29-87-1, IEB-80-11, NUDOCS 8703310326
Download: ML20205F902 (17)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-01 Docket No.50-029 License No. DPR-3 Category _C,

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Licensee: Yankee Nuclear Power Station 1671 Worcester Road Framingham, Massachusetts Facility Name: Yankee Nuclear Power Station Inspection At: Framingham and Rowe, Massachusetts Inspection Conducted: January 27-30, 1987 Inspectors: /k A- D A. A. Varela, Lead Reactor Engineer 1' N'

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NRC Contact Personnel: M. E. Nitzel, EG&G, Idaho V. B. Call, EG&G, Idaho Approved by: ) > < q ,k.; J/$c> 87 (date(

pProcessesSection,EB,DRS U R. Strodni'dsr, Chief, Materfal and Inspection Summay : Inspection on January 27-30, 1987 (Inspection Report No. 30-029/87-01 Areas Inspected: A special announced inspection by a regional-based inspector and two contractor personnel was conducted at the licensee's engineering office and the Yankee Rowe plant site. The inspection encompassed review of licensee responses and subsequent analysis and modifications of masonry walls related to IE Bulletin 80-11, Masonry Wall Design. The inspection included a walkdown of existing walls affecting safety related equipment, a review of

. design analyses and a review of work packages on wall modification Results: One violatii sas identifie h[OUkObbK

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j DETAILS 1.0 Persons Contacted

, Yankee Atomic Electric Company (YAEC)

) *J. DeVincentis, Vice President

*D. F. Grimes, Construction Engineer j

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• J. D. Hazeltine, Project Manager

• B. W. Holmgren, Lead Mechanical Engineer

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• G. Jones, Engineering Manager

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• R. LeFrancois, Mechanical Engineer

• L. Martin, Vendor QA, Supervisor

• M. Mitchell, Maintenance Support Supervisor

• Papanic, Jr., Licensing Engineer i * M. Shepard, Director of Quality Assurance I

Chas T. Main, Inc.

i j 0. Gustafson, Structural Engineer

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NRC Contractor EG&G Idaho, In *V. B. Call, Senior Engineer

• E. M. Nitzel, Engineer Specialist J

l * Attendees at exit meeting on January 30, 1987

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, Inspection Purpose and Scope f The purpose of this inspection was to review at the corporate office and 4 the plant the completeness of the licensee's responses to NRC/IE Bulletin l 80-11, Masonry Wall Design. The scope of the inspection included a review >

of engineering design and quality assurance documentation relating to l inspection, testing, analysis and modification satisfying requirements and

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licensee commitments with respect to the bulletin. A walkdown inspection i of the plant verified repairs and/or modifications relating to the bul-

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I Review Criteria The bulletin defined the required actions by the utilit In addition,

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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.

l Review of Licensee Responses

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a The inspection team reviewed bulletin responses available from NRC files

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prior to the inspection. These responses included correspondence between the licensee and the NRC staff regarding the relationship of bulletin

, activities and Systematic Evaluation Program (SEP) requirements, reports

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addressing the reevaluation methodology, acceptance criteria, wall con-

figurations and functions, structural adequacy, proposed modification j plans, and modification schedules. Table 1 lists those documents reviewed l prior to the on-site inspections. Any items requiring further discussion j were noted as items to be addressed while at the corporate office or plant site. Questions relating to licensee responses were forwarded to licensee i in advance of the inspection as a preliminary agenda for discussio ,

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These are identified in Table The inspection team reviewed additional material provided by the licensee during the inspection. This material consisted of correspondence regard-ing bulletin related work scope, work instructions governing wall survey

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activities, wall survey forms, modification calculations and associated drawings, concrete block and mortar test results, and job order file information regarding the masonry wall modifications made in the turbine

, building. The pertinent documents described above for IEB 80-11 are listed in Tables 2 and 3.

l Findings:

As indicated in the previous section, Yankee Rowe is included in the older operating plants which have been under review as part of the SEP. The Yankee Rowe licensee had requested that IEB 80-11 issues be handled in i conjunction with certain of the SEP topics; thus, an understanding of the l SEP is helpful in following the chronology of bulletin response activi-

ties. The following synopsis of SEP events related to masonry walls at

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Yankee Rowe is intended only as an introduction.

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The SEP was initiated by the NRC in 1977 to review the designs of older

{ operating nuclear power plants and to document their safety when compared j against more recent acceptance criteri Under SEP seismic reevaluation,

! these older plants were categorized into two groups based upon the

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original seismic design and the availability of seismic design documenta-tion. Group I included those plants that had some original seismic l analysis even though these analyses were not consistent with current

! standards. Group II included those plants whose original design did not i include seismic analyses. Yankee Rowe was placed in Group II for the

{ purposes of the SEP.

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! IEB 80-11 was issued on May 8, 1980. Also in 1980 the licensee undertook

! inspections of masonry walls as required by the bulletin and as part of the activities to address SEP topics. In a letter to the NRC dated December 14, 1981, the licensee requested to be permitted to pursue IEB

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80-11 as part of the SEP effor By letter dated December 31, 1981, the l NRC-NRR, SEB Branch agreed that IEB 80-11 could be satisfied as part of j the SEP effort. However this only granted the licensee an extension of

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time in reevaluation of block walls and in reporting the results of the seismic analysis of the wall It did not relieve the licensee from the responsibility of fulfilling item number 1 of the bulletin's 60 day re-quirement. This item addresses the need of performing a detailed as-built survey of all masonry walls in proximity to or that have attachments from safety-related piping or equipment such that wall failure could affect a safety related syste The importance of this survey is underscored by two other sixty day reporting requirements of the bulletin. They are:

(1) to establish a prioritized program for the reevaluation of the masonry walls and, (2) to justify by test or conservative assumptions the acceptance criteria used in the reevaluatio The licensee has stated that during the period spanning approximately 1982 to the present time the SEP work scope had undergone numerous change This has affected the IEB 80-11 actions'due to the fact that the identity of all walls subject to bulletin action has never been formally and com-pletely determined. While it was found that the procedural control over the licensee's initial survey activities was pcor, the number of walls subject to action was also influenced by the negotiations over the differ-ences between what the licensee had proposed and what the NRC desired in the SEP work scope for such topics as wind and tornado loading (SEP topic III-2) and seismic loading (SEP topic III-6). This resulted in the gen-eral finding during the inspection that the licensee has not identified all walls subject to bulletin action and does not have reevaluation cal-culations demonstrating structural adequacy for all leadings as required by the bulletin. The licensee states that the delays incurred in fully complying with IEB 80-11 requirements are due to the changing work scope and that the existing calculations and modifications are considered pre-liminary until such time as the SEP requirements are finalize One violation and three inspector follow-up items resulted from the inspection team's reviews of the licensee's activities regarding IEB 80-11. Further details regarding these items are given below:

Violation:

During the inspection it was determined that several surveys of masonry walls had been performed by both the licensee and contractor group Criterion V of Appendix B to 10 CFR 50 states in part that " Activities affecting quality shall be prescribed by documented instructions, pro-cedures...." Further, it states, " Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accom-plished." The licensee's Quality Assurance (QA) program incorporated 10 CFR 50, Appendix B, prior to the issuance of the bulletin. Also, Action Item 1 of IEB 80-11 requires that the licensee " identify all masonry walls in your facility which are in proximity to or have attach-ments from safety-related piping or equipment such that wall failure could affect a safety related system." Action Item 4 of IEB 80-11 requires that the identity of the subject walls be reported within 60 days of the issuance of the bulletin. The licensee performed a masonry wall survey during June of 1980 which was used as the basis of the required 60 day

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{ response transmitted in a letter dated July 8, 1980. However, contrary to i

the requirements of 10 CFR 50, Appendix B, the June 1980 wall survey was performed without utilizing documented and controlled procedures. While 2 the licensee met the 60 day report date required by the bulletin, without

documented procedures governing the survey process it could not be sub-

, sequently confirmed by the inspection team that all walls subject to 1 action as defined by the bulletin and required to be addressed at that time were included in the effort. This lack of procedural control over

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i the earlier survey activities is a violation of 10 CFR 50, Appendix B, Criterion V (50-029/87-01-01). The June 1980, survey and the 60 day res-j ponse of July 8,1980, were completed prior to the agreement with the NRC

(NRR) that the bulletin could be handled under the SEP. Since the lic-ensee had committed to 10 CFR 50, Appendix 8, prior to issuance of the bulletin and the SEP agreement, its requirements would apply in any case.

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Also, the full requirements of IEB 80-11 would be applicable up to the date of the SEP/IEB 80-11 agreement which actually only effectively

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allowed for schedule changes and work scope modifications. SEP program

! management personnel have stated that it was their intention that all i ether bulletin requirements be satisfie ;

5.0 Inspector Follow-up Items I During the inspection, the licensee was asked what measures were l being taken to assure that the physical condition (absence of cracks,

! boundary conditions, etc.) of the walls would be maintained. The t

licensee stated that periodic surveillance of the subject masonry

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walls would be performed to ensure that the physical conditions I

i assumed during the recent re-analysis effort remain valid, however, a procedure for this surveillance activity had not yet been

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developed. The licensee added that although a final procedure will not be completed until the SEP topics affecting masonry walls are

! completely resolved a draft of the procedure for continued surveil-i lance of masonry walls will be available for NRC Region I review within four weeks of the receipt of this inspection repor The NRC

, will follow up on this item in a future inspection.

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l Action Item 1 of IEB 80-11 requires that the licensee " Identify all

masonry walls in your facility which are in proximity to or have

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attachments from safety-related piping or equipment such that wall i failure could affect a safety-related system." As explained in the

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previous section (Violation), the inspection team could not confirm

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that all masonry walls subject to action had initially been identi-fied as required. During the inspection, the licensee stated that

! another masonry wall survey effort was currently underway. This l survey was being conducted using a documented procedure; however, the l survey effort was not completed. The licensee stated that the re-l suits of this survey would contain a complete list of all masonry

! walls subject to action under the current SEP work scope. This list i . of walls would also constitute the most current version of the in-j formation required under IEB 80-11 Action item The inspector

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requested that this list be provided to the NRC Region I office at the earliest possible date. The licensee stated that this informa-tion would be submitted to NRC Region I within four weeks from the receipt of the SEP safety evaluation reports (SER's) which concur with the licensee's list of masonry walls subject to bulletin actio It was noted that these SERs are expected to be received in late February or early March 198 . Action item 2 of IEB 80-11 requires the demonstration of the struct-ural adequacy of all subject masonry walls. Action item 4 also sets reporting dates for this requirement. It was determined that the licensee currently does not have reevaluation calculations clearly showing the structural adequacy of all masonry as required. It was found that the licensee advised the NRC Region I office (July 8, 1980, submittal) that structural adequacy calculations would be de-layed while seismic response spectra were developed for the plan Subsequently (December 31, 1981), the licensee obtained permission to include bulletin activities under their SEP work scope. The inspec-tor requested that the licensee provide a list of all masonry walls '

subject to bulletin action correlated to their structural adequacy status under the criteria agreed to under the SEP at the earliest possible time. The inspector also requested that a modification schedule be provided, when available, for any walls which do not meet the agreed upon SEP structural adequacy criteria. The licensee

!.tated that a report on the wall status will compare the structural adequacy of each masonry wall subject to bulletin action to the acceptance criteria defined in the SEP SER's mentioned above. This will be provided to the NRC Region I within 60 days of the receipt of the SER's. The licensee also stated a proposed schedule for the reevaluation calculations and/or modifications for all walls which do not meet the criteria defined in the SERs will be submitted to Region . Verification Walkdown Inspection A physical inspection of certain masonry walls subject to bulletin action was conducted. The walls included in this sample were chosen by the in-spection tea The purpose of this walkdown was to verify samples of inspections and/or modifications required by the bulletin. The walls shown in Table 4 were examined. The walkdown activities concentrated on determining if the physical characteristics of the walls, as observed in the plant, reasonably matched the data used in the wall calculation Examples of those items spot checked during the walkdown include overall dimensions, bond type, number of lifts, boundary conditions, attached equipment, and equipment in proximit Findings: No unresolved item resulted from the plant walkdow .

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Licensee Administrative Controls and Assurance of Quality An inspection was performed of licensee's administrative controls and i

assurance of quality in his activities relating to NRC/IE Bulletin Masonry Wall Design. The pertinent documents reviewed and discussed with cognizant personnel are listed in Table 5. Based on the above examination and review, the inspector determined that the administrative controls governing engineering services of C. T. Main, of YAEC engineering depart-ment and, the contract work on wall modification was adequate and effect-ive to assure quality. Sufficient inspections and verifications conformed to established requirements, specifications, and drawings. However, as stated in paragraph 4, the licensee has not yet identified all walls sub-ject to the bulletin and does not have reevaluation calculations demon-strating structural adequacy for all loadings as required by the bulleti Additionally the licensee's procedure presently being used to resurvey  !

masonry walls left collection of accurate physical data to the discretion of the individual. It was observed that this procedure instructed per-sonnel to identify masonry walls located in proximity to or supporting specific Safe Shutdown System piping, equipment, and structures. However, it did not clearly instruct which physical data (such as wall length, height, bond type, block size, existing cracking, attachment weights and locations, etc.) should be noted such that an accurate analysis could be performed. This procedure could have been written to provide more complete direction. Clearer direction documented in the procedure would have provided a " checklist" for use during the surveys and further ensured consistency of results. However, review of a sample of the wall survey sheets and their associated drawings revealed no omissions of pertinent data. The inspector had no further questions regarding this matter at this tim . Conclusion Based on the results of this inspection and, pending licensee response to the violation and inspector follow-up items IEB 80-11 remains ope . Exit Meeting An exit meeting was conducted on January 30, 1987 by the NRC inspecto Attendees at the meeting are listed in paragraph The NRC inspector summarized the inspection findings and the licensee acknowledged these comment No written material, other than that described in paragraph 4 (preliminary agenda for discussion) was furnished to licensee personne Subsequent to this meeting, after further review of licensee responses and evaluation of documentation pertaining to IEB 80-11 and SEP, in telephone communications of February 6 and 19, 1987 the licensee was notified of the violation resulting from this inspectio ... . - ---

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TABLE I - DOCUMENTATION REVIEWED PRIOR TO INSPECTION Document Description

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L. H. Heider (YAEC) letter to B. H. Grier (NRC) dated 7-8-80 transmitting plant survey information regarding masonry wall J. P. Knight (NRC) memorandum to E. L. Jordan (NRC)

dated 10-7-80 requesting additional information i regarding bulletin activities at Yankee Row E. L. Jordan memorandum to B. H. Grier transmitting the request for additional information regarding bulletin activitie DCD-2648-6-1 Structural design criteria for evaluation and modification of existing masonry block walls - report

by C. T. Main consulting engineers dated 2-8-84.

I ER-2648-10-2 Summary design report for block wall modifications

inside the turbine building - report by C. T. Main consulting engineers dated 5-10-8 M. N. Shulman (CYGNA) letter to B. W. Holmgren (YAEC)

transmitting draft replies to NRC questions regarding Systematic Evaluation Program (SEP) topics (informa-tion included regarding masonry walls).

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G. Papanic (YAEC) letter to E. McKenna (NRC) dated 10-1-86 transmitting licensee responses to NRC 4 questions relating to masonry wall seismic evalua-tion M. N. Shulman letter to B. W. Holmgren dated 12-18-86 transmitting revision three of " Seismic Re-evaluation and Retrofit Criteria", DC-1.

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, TABLE 2 - DOCUMENTATION REVIEWED DURING INSPECTION

Document Description

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J. Kay (YAEC) letter to D. Eisenhut (NRC-NRR) dated 12-14-81 transmitting proposed YAEC seismic evaluation program. This letter proposed that IEB 80-11 be handled under SEP work scop D. Crutchfield (NRC-SEP) letter to J. Kay dated 12-31-81. This letter included agreement that the licensee could handle IEB 80-11 under SEP work scop YR-WI-12 YAEC work instruction for identification of masonry walls near SSS piping and equipment (dated 1-12-87).

E-07 C. T. Main (Main) procedure for the preparation, documentation, and control of calculation Letter from McDonnell Douglas Automation Co. to C. T. Main transmitting certification for MCAUTO STRUDL quality assuranc E-27 Main procedure for the verification of computer programs.

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E-Y-YR-81033-1 CYGNA Energy Services (CYGNA) report on the prelim-inary review of masonry walls at Yankee Nuclear Power Station (dated 10-81).

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Main project procedures manual for concrete block wall evaluation and modificatio YAEC request for proposal letter to various vendors transmitting criteria for the analysis of concrete i

block walls near hot shutdown system equipment and for the design of wall upgrades at YNPS (dated

6-29-83).

ER-2648-6-1 Main structural evaluation for tornado cost / benefit analysi HB-1 YNPS amplified response spectra and seismic anchor motion handbook for seismic analysis (prepared by CYGNA).

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Main masonry wall survey forms (surveys performed in 1983) for walls T2H3, T2H4, T293, T2G3, T2G4, T1121, T1H2, T2HS, P1El, PIE __ __ -- _________ _ _ _ . . _ . _ _ . _ . _ __ _

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(Continued) TABLE 2 - DOCUMENTATION REVIEWED PRIOR TO INSPECTION Document Description YR-WI-12, Att. C Masonry wall survey sheets from January,1987, YAEC survey effor Engineering Design Change Request (EDCR) close out

documentation for masonry modifications inside the turbine buildin YAEC QC inspection report for modifications made to the PAB north wall, upper pipe chase, and cable tray hous WE-100 YAEC engineering instruction for the coordination of processing of EDCR WE-101 YAEC engineering instruction for the design review of EDCRs. This document contains guidance regarding proper notification to engineering groups for modifi-

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cations to safety-related masonry walls.

! JO 84-413 YAEC job order file containing complete documentation such as checklists, material certs, QC reports, et for the modifications made to certain masonry walls

, in the turbine building.

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, 3 Table 3 - MODIFICATION PACKAGES REVIEWED Wall' Elev. (ft) Field Inspection T2H3 1037' 8" Yes T293 1037' 8" Yes T2G3 1037' 8" Yes

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T2G4 1037' 8" Yes T1121 1022' 8" No I

T1H2 1022' 8" No T2H6 1037' 8" Yes PIE 1 1022' 8" Yes PIE 2 1022' 8" Yes

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Review of the modifications listed above included cursory examination of the calculations, examination of the as-built drawings, quality control records, and field inspection as noted. A detailed examination of the calculations was not performed because this had already been accomplished as part of the inde-i pendent audits performed by NRC contractors as part of the SEP revie ,

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l- 4 l Table 4 - MASONRY WALLS FIELD VERIFIED ,

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Wall Elev. (ft) Location T3121 1052'-8" Turbine Building '

i T3H4 1052'-8" Turbine Building i T2H4 1037'-8" Turbine Building

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i T292 1037'-8" Turbine Building T2G3 1037'-8" Turbine Building

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T2H3 1037'-8" Turbine Building T293 1037'-8" Turbine Building T3G1 1052'-8" Turbine Building T2H5 1037'-8" Turbine Building T2121 1037'-8" Turbine Building PIE 1 1022'-8" Primary Aux. Bld PIE 2 1022'-8" Primary Aux. Bld P2F1 1039'-6" Primary Aux. Bld ;

P2F2 1039'-6" Primary Aux. Bldg.

D1Z2 1022'-8" D. G. Annex i D11053 1022'-8' D. G. Annex

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P363 1056'-6" Upper Pipe Chase

_ P3F2 1056'-6" Upper Pipe Chase l P362 1056'-6" Upper Pipe Chase

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Table 5 - Documentation of Licensee Administrative Controls l Y0QAP-1-A Operational Quality Assurance Manual

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EDCR 83-35 Turbine Building SEP Modifications and support to Close-Out exist in block walls EDCR 84-317 Masonry Wall Modifications inside Turbine Building Close-Out and Switch Gear Room i EDCR 86-305 Masonry Wall SEP Modifications upper Pipe Trace and 1 Close-Out Cable Tray House EDCR 86-305 Masonry Wall SEP Modifications, Examination Data QC Visual Sheets YAEC Internal Audit NSD 86-12, July 1986 Annual audit of Yankee Plant Project Engineering Department YAEC Vendor Evaluation Report #83-26-2 of C. T. Main, Inc Quality Assurance Manual and Verification of its implementation YAEC Engineering Instruction WE-203, Request for bids / vendor proposal for material, equipment and/or services YAEC Engineering Instruction, WE-205, Bid Evaluation and procurement i

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Table 6 - Request for Information The following is a list of preliminary requests for information pertinent to actions taken in response to the subject bulleti It is planned that the responses to these requests will be reviewed and discussed during the inspectio . What procedure was used to identify masonry walls subject to bulletin action? Provide a copy for revie . Several field surveys of the masonry walls have apparently been conducted. Provide information describing the performing organization and intended end use of the data from all masonry wall field survey . What procedure was used by each performing organization to complete the wall data sheets or survey forms? What was the " mix" of data sources used to acquire information on each wall in the reanalysis effort; ie.,

were these data based primarily on field surveys, construction records or other sources?

' Provide the procedure (s) used and marked up drawings or other first generation field documentation showing results obtained from all field surveys conducted for use in the masonry wall reevaluation effor . What QA/QC oversight was applied to performance of surveys and accuracy of results? Do any safety related piping systems have supports attacned to the

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subject walls?

I Provide documentation of QA oversight / audits of all contract organizations involved in bulletin actions.

Information regarding all walls subject to bulletin action should be readily available for review by the inspection team; however due to the

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number of walls it is expected that a sample will be audited. To enable the selection process to be completed, a table containing the following information is requested for all walls subject to bulletin action:

Wall identification or designation i

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Location Elevation Wall dimensions (length, height, thickness)

Number of wythes Boundary conditions Reinforced or unreinforced Bond type (stacked or running)

Calculated frequency (or frequencies)

Reevaluation stress levels calculated prior to modification (if applicable)

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Wall stress levels after modification (if applicable)

Analysis technique used

. Qualification criteria (ACI Code, arching, energy balance, etc.)

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The reevaluation calculations and complete modification packages (where applicable) should be immediately available for review at the beginning of the inspection. Modification packages should include all stress calcula-tions, design / construction drawings, QC documentation and any other per-tinent information such as nonconformance reports (NCR's) and their dis-positions that may exi . Provide the surveillance plan for routine inspection to assure the continued validity of assumed boundary conditions, physical condition (such as absence of cracks) and continued structural adequac . Describe the procedure (s) used to control additions to or changes in the configurations of the masonry walls subject to bulletin actio Provide

copies for revie . Have any recent resurveys been undertaken to ascertain tha' c plant i modifications or regulatory requirements made in the intervening time since 1980 have not changed the status or classification of any masonry walls?

12. Were any unreinforced walls found to have cracks? If so,

, Which walls were found to contain cracks?

' Were they analyzed to account for the cracked sections? Were the cracks repaired or was any other corrective action taken? If the cracks were repaired provide the governing procedure and samples of documentation demonstrating successful repair completio . Were any computer codes other than McAUTO STRUDL and STRPOST1 used in the wall reevaluations? Also, identify which groups or organizations used

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them.

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14. Were all computer codes used " benchmarked?" If so, provide documentatio . Was the post processing computer program STRPOSTI developed internally by C. T. Main? If not, who was the author / vendor? Provide documentation of the QA/QC process used in the program development and the results of the

" benchmark" run . What procedure (s) were used to assure that computer codes were used properly to obtain accurate results? Provide copies for review.

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l 1 Provide a copy of C. T. Main (MAIN) procedure E-07 for review. The I revision supplied should be that in effect during the performance of the reevaluation tas . Provide a copy of the MAIN project procedure manual referred to in section 3 of MAIN report DCD-2648-6- . Reference h in section 2 of MAIN report DCD-2648-6-1 refers to revision 2 of document number DC-1 by CYGNA Energy Services. How was the CYGNA criteria applied by MAIN? Where differences occurred between the CYGNA and MAIN criteria, which one controlled or was applied?

20. Section 5.b of MAIN report DCD-2648-6-1 states that " selection of appropriate ARS shall be in accordance with CYGNA guidelines." Clari fy what the CYGNA guidelines are and how they were applied. The complete package of response spectra should also be available for referenc . Referring to section 14 of MAIN report DCD-2648-6-1, which walls were initially modeled to include ":reliminary fixes / modifications? What procedure and/or criteria was used to make these determinations?

22. What are the "special conditions for Yankee Atomic Electric Company (YAEC)" referred to in section 2 of MAIN procedure MFP-17 23. What criteria determined an " insignificant" attachment load as mentioned in section 3.2 of procedure MFP-17 24. Clarify the status of wall P2G3. This wall is listed in the table of ;

walls shown as Attachment A to procedure MFP-1 but was not found to be addressed in the report on the primary auxiliary building (PAB) masonry wall . Provide information comparing the results of the confirmatory analyses of masonry walls using NRC response spectr . Information provided indicates that only those walls suppurting or near safe shutdown system (SSS) equipment were considered in the reevaluation program. Clarify whether this was indeed the work scope that was pursued. If so, was this work scope agreed to by the NRC? Provide documentatio . What masonry walls within the plant would be considered safety-related (consistent with definitions in Reg. Guide 1.29) that are not included in the group covered by the SSS scope of work?

28. The response to systematic evaluation program (SEP) item 12A (dated November 4-6,1986) states that arching action may be used if walls are not qualified elastically. Was arching action used to qualify any masonry walls?

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29. Provide a " quick reference table" listing those walls that were modified and the associated modification approach (such as removing deficient construction, reinforcing with steel members, etc.) that was use . Maximum stress ratios in walls T1H2 and T2121 were 0.89 and 0.91 respectively. What were the results when NRC spectra are considered?

31. Clarify how the diesel generator building provides out of plant restraint to walls PIE 2 and P2F . How were actual boundary conditions verified as required by MAIN document DCD-2648-6-1, section 5.d? For example, what measures were taken to verify the actual condition of the #6 bars at the UPC wall /RPT roof salb joint?

33. Provide further justification for the acceptability of the overstressed walls in Table 1 of section 5.2 of MAIN report ER-2648-10- . How would the results for the walls and structures described in MAIN report ER-2648-10-2 change when NRC spectra are considered?

35. What actions are planned or have been completed to remedy the structural steel connection deficiencies noted in section 5.5 of MAIN report ER-2648-10-2?

3 Enclosure 1, Attachment 1-3, of the 10-1-86 submittal (G. Papanic letter to E. McKenna) includes test results for concrete block and mortar. What QA/QC program and procedures were applied to these tests?

37. How was the existence and location / spacing of rebar verified?

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