ML20153D074

Insp Repts 50-277/88-30 & 50-278/88-30 on 880815-19. Violations Noted.Major Areas Inspected:Adequacy of Licensee Actions in Response to IE Bulletin 80-11 & Adequacy of Corrective Actions in Response to Violation 87-16-01

ML20153D074
Person / Time
Site:	Peach Bottom
Issue date:	08/25/1988
From:	Carrasco J, Chaudhary S, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153D054	List: ML20153D052 ML20153D069 ML20153D074
References
50-277-88-30, 50-278-88-30, IEB-80-11, NUDOCS 8809020032
Download: ML20153D074 (8)

See also: IR 05000277/1988030

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

Report Nos.

50-277/88-30

50-278/88-30

Docket Nos.

50-277

50-278

License No.

OPR-44

DPR-56

Licensee:

Philadelphia Electric Company

2301 Market Street

Philadelphia Pennsylvania 19101

Facility Name: Peach Bottom Atomic Power Station, Units 2 and 3

Inspection At: ' Delta Pennsylvania

Inspection Dates: August 15-19, 1988

Inspectors:

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S. K. Chaudhary, Lead Reactor Engineer,

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J. LL.Cattasco, Reactor Engineer, MPS, EB,

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DRS Region I

Approved by:

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[Jf. Str2fnide'r,~ Chief, Materials &frocesses

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v5ection, Engineering Branch, DRS,6R1

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Inspection Summary: Routine unannounced inspection on August 15-19, 1988

{ReportNos. 50-277/88-30 and 50-278/88-30)

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Areas Inspected: Adequacy of licensee actions in response to NRC IE

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Bulletin 80-11;

adequacy of corrective actions in response to violation

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87-16-01; and to review additional information to resolve the unresolved

item 87-16-02.

Results: One violation with several examples was identified.

The violation

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consisted of inadequate inspections of modifications to masonry walls to

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assure quality.

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DETAILS

1.0 Persons Contacted

Philadelphia Electric Company

• J. Franz, Plant Manager

• 0. McGarrigan, Superintendent, Quality Control

• J. Pratt,. Perch Bottom Atomic Power Station, Manager, Quality

• J. Netzer, Superintendent, PS&R for Projects.

• 0. Smith, Vice President, Peach Bottom Atomic Power Station

• T. Cribbe, Regulatory Engineer

• G. Hanson, Regulator Engineer

• A. Hegeohs, Site Project Engineer, Nuclear Energy Division

• 0. Torone, Modification Installation Engineer

• P. Hinnbnuamp, Administrative Assistant, Modifications

Bechtel Power Corporation

• E. Patel, Project Engineer

United States Nuclear Regulatory Commission

• T. Johnson, Senior Resident Inspector

• Denotes those attending the exit meeting.

The inspectors also contacted other administrative and technical personnel

during the inspection.

2.0 Inspection Purpose and Scope

The purpose of this inspection was to review the adequacy of: licensee

actions in response to NRC Bulletin 80-11, Masonry wall design; adequacy

of corrective actions in response to violation 87-16-01; and to review

additional information for the unresolved item 87-16-02.

Particular

emphasis was placed on determining the technical adequacy of design and

installation of modifications to the identified walls, and the status of

licensee commitments made to the NRC during the last inspection in this

area (19 87-16).

The documents reviewed during this inspection are listed

in Attachment A.

3.0 Liceasee's Actions on Previous NRC Concerns

(Closed) Violation (87-16-01):

This violation pertained to a lack of

written procedures describing the scope and qualitative /quantitatiYe

acceptance criteria for walkdown surveys of block walls performed in

response to IE Bulletin 80-11.

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The licensee has developed, approvea, and implemented a procedure to

document the scope and acceptance criteria for block wall surveys, and

has resurveyed block walls according to the requirements of this

procedure.

This item is closed. (50-277;50-278)

(Closed) Unresolved Item (87-16-02);_ This item pertained to the

separation of masonry walls from reinforced concrete walls at the boundary

interface. These separations (through cracks) were at the boundary where

positive connections had been assumed in the analysis to evaluate the

safety of the wall..

The licensee has implemented a program of chipping and drilling of block

walls at interfaces to positively identify if connections between block

walls and reinforced concrete walls do exist.

This item is closed. (50-277; 50-278)

4.0 Installation of Modifications

Concrete Expansion Anchor Bolts

The inspector performed a walk through inspection of Units 2 and 3 to

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visually examine the status of masonry walls and blockouts.

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inspection consisted of random verification of walls and blockouts to

determine whether their configuration and location matched those shown on

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the design drawings and survey results. An independent verification of

torque values for the concrete expansion anchors was also performed.

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The inspector selected wall numbers 76.6 and 76.10 in the reactor

building, and wall number 16.1 in the reactor core isolation cooling

(RCIC) room in Unit 2.

In Unit 3, wall number 413.1 in the reactor

building was selected.

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The inspector requested the licensee to randomly verify the installed

torque in the concrete expansion anchor bolts installed in the foregoing

listed structural concrete walls.

The licensee provided a Quality Control

inspector and a crew with a calibrated torque wrench (number 54-6028) to

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perform the requested verifications.

Based on the above examination and

independent torque verification the inspector determined the following:

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In wall 76.6 at elevation 165'-0" in the reactor building, 11 bolts

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of a sample of 26 failed to indicated the minimum specified torque of

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85 foot pounds.

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Wall 76.10 at elevation 165'-0" in the reactor building, two out of

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three bolts failed to indicate the minimum specified torque value.

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In wall 16.1 at elevation 88'-0" in the RCIC room, nine bolts out of

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18 failed to indicate the mit.imum specified torque.

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In Unit 3 wall number 413.1 in the reactor building elevation

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165'-0", modifications had not been completed. The inspector did not.

verify the torquing.

Based on the above observations the inspector determined that the

licensee's inspection prccedure for verifying the acceptable installation

and torquing of concrete expansion anchors was inadequate to assure proper

installation.

10 CFR 50, Appendix.B, Criterion X, requires an adequate

inspection program to verify conformance with the documented instructions,

procedures and drawings for accomplishing the activity.

This is a

violation of this requirement (50-277/88-30-01).

Furthermore, the inspector observed that the quality control verification

of proper torquing of concrete expansion anchors was based on sampling.

The licensee's procedure CD 5.12, installation of Concrete Expansion Bolts,

requires 1 in 5 installed anchors (20%) to be verified by Quality Control

for proper torquing.

The procedure was developed for IE Bulletin 79-02

which allowed sampling, but the sampling was based on a rigid

statistical analysis of a large population of bolts encountered in the

veri.fication required by the Bulletin.

The sampling plan of Bulletin 79-02 required a 95% confidence limit.

The same sampling method / criteria

used in the modification work without sufficient justification for

determining the 95% confidence limit required by the Bulletin is improper

when the sample size is changed.

Especially, in view of the large number

of bolt failures to meet the specified torque, raises a serious question

as to the odequacy of this inspection criteria.

Installation of Structural Steel

The inspector reviewed the Quality Control documentation (Structural Steel

Installation Form, CD 5.6-111) and visually examined the installed

modification to the interfaces of block and structural concrete walls to

the verify the adequacy of inspection criteria and acceptability of the

workmanship.

These examinations were conducted in conjunction with the

independent verification of anchor bolt torquing in the reactor building,

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The inspector noted that the licensee's procedure, CD 5.6 Revision 5,

Installation of Pipe Supports and Structural Steel, references the

American Institute of Steel Construction (AISC) Code for design,

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fabrication, and installation of structural steel.

The licensee's

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procedure requires inspection and verification of bolt holes for size and

acceptrbility of fabrication of pipe supports but does not require a

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similar inspection for structural steel.

The procedure also does not

include an attribute for verification of acceptable fabrication and

alignment of bcit holes to the previously installed concrete expansion

anchors.

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The AISC Code for design, fabrication, and installation of structural

steel recommends verification of bolt hole locations and alignment of

connections. The spacing of anchors is primarily controlled by the

reinforcement bars in the structural concrete encountered during the

drilling for anchors. Therefore, structural members must be fabricated so

that the bolt holes are properly aligned with the installed anchor bolts.

The inspector observed that during installation of the shop fabricated

structural members the acceptability of bolt holes had not been verified

by Quality Control.

The structural steel inspection, as implemented for

the modification (modification 2235), was inadequate in that the

installation and inspection procedures do not require inspection /

verification of bolt holes for acceptability; such as, size of hole,

shape of hole, process by which hole was made (drilling, punching,

burning), and the location of holes to match the installed anchors.

This

also is a violation of 10CFR 50, Appendix B, Criterion X, which requires

examinations, measurements, or tests of material or products processed for

each work operation where necessery to assure quality. Further,10 CFR 50,

Appendix A provides that structures be designed and fabricated in ac-

cordance with quality standards commensurate with their relative

importance to safety (50-277/88-30-02).

5.0 Engineering and Design Control

The inspector reviewed documentation and held discussions with licensee

personnel to determine the adequacy of identification of block walls,

analysis and evaluation of their current function and design bases. This

review was to assure that the analyses and evaluations were technically

valid and properly documented to support the modifications designed for

walls and blockouts.

The review covered engineering calculations, design

drawings and management controls exercised over the process. Based on the

above review and discussions the inspector determined that:

The licensee had engaged the services of Bechtel Power Corporation

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for analyses and evaluation of walls and design of modifications.

The licensee identified 22 walls that required modification to meet

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the requirements of Bulletin 80-11.

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The analyses, evaluations and modifications were performed properly,

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were technically valid, and properly documented.

The records were

readily retrievable and Bechtel had applied adequate control measures

to assure the validity of the design process.

However, the inspector determined that no formal mechanism or program

existed to assure that the newly assigned wall and blockout designations

were transferred to permanent design drawings for traceability of records

and modifications.

The licensee initiated an engineering request form

(ERF) to amend the modification package to revise the drawings to include

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the wall and blockout designations.

This ERF was approved by management

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before the inspector left the site.

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Configuration Control of Masonry Walls

During a previous NRC inspection (IR 87-16) the inspector was informed

that the licensee was developing a procecere to establish a surveillance

and/or inspection for masonry walls to assure that the walls /blockouts

remained in the same condition and configuration as analyzed.

The

inspector determined that no such program or procedure has been developed

and implemented as of the date of this inspection. The inspector

requested the licensee to provide a schedule for developing and

implementing such a program.

An second commitment for control of additional loads on masonry walls (PE

letter of 12/2/87 Kemper to Johnston) has been fulfilled. The licensee

has initiated procedure M-701, Revision 0, to control new loads.

6.0 Control of Nonconformances

During the review of Quality Assurance documentation the inspector

identified one nonconformance report (NCR), CD-P-1469, which was written

against the grouting operations of structural steel members in the masonry

wall modifications.

The NCR indicated no inspection or verification for

acceptability of grout or the grouting operation had been performed by

Quality Control.

However, the NCR was dispositioned by the licensee's

consultant (Bechtel) as "use-as-is".

The rationale provided for this

disposition was that the grouting operation was acceptable since the

preparation of the concrete surface to be grouted, and mixing placing and

curing of grout was performed in accordance with manufacturers

instructions.

The grout is applied to fill voids and gaps between the

walls and structural steel to ensure load bearing areas are adequate.

The

inspector requested the licensee provide the basis of this rationale in

the absence of any objec;;ve supporting evidence.

The licensee was unable

to produce any objective evidence to justify such a rationale by the

dispostioning engineer.

Visual inspection after installation cannot

provide convincing evidence attesting to the adequacy of the grout.

No

independent, direct inspection, 'xamination or test had been performed to

establish the acceptability of the ; rout and the grouting operation.

10 CFR 50, Appendix B, Criterion X, requires examination, measurements or

tests of material or products be performed for each work operation where

necessary to assure quality.

This is another example of inadequate

implementation of the Inspection program of the licensee.

This is a

violation (50-277/88-30-03).

7.0 Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items or violations.

Unresolved items are discussed in paragraph 3.0.

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8.0 Management Meetings

Licensee management was informed of the scope and purpose of the

inspection at the entrance interview on August 15, 1988 The findings of

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the inspection were discussed with licensee representatives during the

course of the inspection and presented to licensee management at the

August 19, 1988 exit interview (see paragraph I for attendees).

At no time during the inspection was written material provided to the

licensee by the inspector.

The licensee did not indicate that proprietary

information was involved within the scope of this inspection.

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ATTACHMENT A

DOCUMENTS REVIEWED

Engineering Calculations

Unit 2

87RE/ACI-25.1

IE-8011/ACI-15.1

87RE/ACI-15.1

87RE/ACI-32.1

87RE/ACI-16.1

87RE/ACI-78.3

87RE/ACI-406.6

87RE/ACI-406.9

Unit 3

87RE/ACI-413.1

Coo _ ling Tower

IE8011/ACI-532.1

Concrete Expansion Data Sheets for Block Walls

Wall Numbers 15.1, 15.2, 16.1 19.2, 25.1,

25.2 76.6, 76.10, 128.1, and 128.2,

Modificaticn Packagg 2235, Section 7, Quality Control Documentation

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