Information Notice 1987-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11
IN 87-67 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555 -
December 31, 1987 NRC INFORMATION NOTICE NO. 87-67: LESSONS LEARNED FROM REGIONAL
INSPECTIONS OF LICENSEE ACTIONS IN
RESPONSE TO IE BULLETIN 80-11
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose
This information notice is being provided to inform addressees of lessons
learned from Nuclear Regulatory Commission (NRC) inspections of certain activi- ties related to the reevaluation work conducted and plant modifications made in
response to Bulletin 80-11, Masonry Wall Design, issued on May 8, 1980. It is
expected that recipients will review the information for applicability to their
facilities and consider actions, as appropriate, to avoid similar problems.
However, suggestions contained in this information notice do not constitute
NRC requirements; therefore, no specific action or written response is required.
Description of Circumstances
IE Bulletin 80-11, Masonry Wall Design, addressed the potential for problems
with the structural adequacy of concrete masonry walls in proximity to or with
attachments to safety-related piping or equipment. In brief, all licensees
for operating nuclear power reactor facilities were required to:
1. identify all masonry walls in each facility that are located in proximity
to or have attachments to safety-related piping or equipment
2. provide a reevaluation of the design adequacy of the subject walls
3. provide written reports of the activities required by the bulletin
While performing inspections to follow up on IE Bulletin 80-11 activities at
several plants, NRC inspectors and consultant personnel noted several defi- ciencies having the potential for affecting plant safety. Some of the types
of deficiencies discovered are described below; specific examples are discussed
in Attachment 1.
8100 ' 10fs-/
IN 87-67 December 31, 1987 Unanalyzed Conditions
Unreinforced masonry walls were discovered to contain cracks that were not
accounted for in the structural analyses of the walls. This situation was
found at several plants and ranged from mortar joint cracks to through-wall
cr~acks in block and mortar. These conditions required remedial action by
licensees after the cracks were discovered.
Improper Assumptions
Several instances were found in different facilities where assumptions made
during the reevaluation analyses for individual walls were either in error or
had not been verified. Items in question included unsubstantiated mortar
properties, faulty assumptions for wall boundary conditions, and assumed
reinforcement that had not been verified. In each case, remedial action was
required by the licensee.
Improper Classification
Classification of masonry walls as safety-related and not safety-related was
also found to be a problem. At one site, it was discovered that five walls
that were not safety-related had been reclassified as safety-related after the
initial IE Bulletin 80-11 work had been completed. However, the reclassified
walls were not reevaluated to verify that the bulletin requirements were met.
Lack of Procedural Controls
Several cases were identified at different facilities where activities were
performed on safety-related components or equipment without proper controls.
These activities included the performance of walkdown surveys, record keeping, and the control of modification activities.
Discussion
The deficiencies regarding unanalyzed conditions and faulty assumptions high- light the need for careful field verification of all critical parameters used
in the qualification by analysis of masonry walls. Use of carefully written
and approved procedures would have helped to prevent overlooking walls subject
to bulletin action during the original surveys. Written procedures governing
reclassification of or modification to the subject walls would have helped to
prevent the failure to evaluate the reclassified or newly installed walls to
the bulletin requirements.
NRC inspectors observed that mechanisms did not exist at certain facilities to
ensure that the physical conditions of masonry walls remained as previously
analyzed. Some licensees have developed programs with procedural controls
requiring engineering notification, reevaluation, and periodic inspections to
ensure that the structural integrity of these walls is maintained. These
programs ensure that the physical condition of the walls, such as lack of
mortar cracking and boundary conditions, remain as analyzed.
IN 87-67 December 31, 1987 No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
iDivision
arles E.Ussi, Director
of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
A. A. Varela
(215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection
Findings with Potential Safety Impact
2. List of Recently Issued NRC Information Notices
I Attachment 2 DIN87-67 December 31, 1987 LIST OFRECENTLY ISSUED
NRC INFORMATION NOTICES 1987 In formation M&lW oT
Notice No. Sublect Issuance Issued to
87-66 Inappropriate Appplication 12/31/87 All holders of OLs
of Commercial-Grade or CPs for nuclear
Components power reactors.
87-28. Air Systems Problems at 12/28/87 All holders of OLs
Supp. 1 U.S. Light Water Reactors or CPs for nucletr
power reactors.
87-65 Plant Operation Beyond 12/23/87 All holders of OLs
Analyzed Conditions or CPs for nuclear
power reactors.
87-64 Conviction for Falsification 1222/87 All nuclear power
of Security Training Records reactor facilities
end all major fuel
facility licensees.
87-35. Reactor Trip Breaker 12/16/87 All holders of OLs
Supp. 1 Westinghouse Nodel OS-416, or CPs for nuclear
Feaied to Open on Manuel power reactors.
Initiation From the Control
Room
87-63 Inadequate Net Positive 12/9/87 All holders of OLs
Suction Read in Low Pressure or CPs for nuclear
Safety Systems power reactors.
87-62 Mechanical Failure of 12/B/87 All holders of OLs
Indicating-Type Fuses or CPs for nuclear
power reactors.
87-61 Failure of Westinghouse 12/7/87 All holders of OLs
W-2-TYPe Circuit Breaker or CPs for nuclear
Cell Switches. power reactors.
87-60 Oepressurization of Reactor 32/4/87 All holders of OLs
Coolant Systems in or CPs for PWRs.
PressuriZed-Water Reactors
- Operating License
- Construction Permit
UNITED STATES
NUCLEAR REGULATORY COMMISSION FIRST CLAS MAIL
POSTAGE t FEES PAID
WASHINGTON, D.C. 20555 USSNRC
PERMIT No. 07 OFFICIAL BUSINESS
PENALTY FOR PRIVATE USE, $300
. I * .
Attachment 1 IN 87-67 December 31, 1987 EXAMPLES OF IE BULLETIN 80-11 INSPECTION FINDINGS
WITH POTENTIAL SAFETY IMPACT
Specific examples of some of the deficiencies discovered during the inspections
performed to follow up on IE Bulletin 80-11 activities and licensee actions to
correct the problems are discussed below.
A. During an inspection conducted at Indian Point, Unit 2, on September 16-20, 1985, the NRC inspectors observed mortar joint cracking in the west and south walls
of the fan house. The licensee proposed an appropriate repair procedure to
fix these cracks. This approach was accepted by the NRC as part of the
licensee's proposed modifications. Inspectors observed evidence of repair
activities during the onsite field walkdown conducted as part of the followup
inspection. However, they also observed the presence of numerous mortar
joint cracks, some of which were in joints that appeared to have been
previously repaired.
The NRC reevaluation acceptance criteria includes a provision for allowing
tension in masonry walls that are not reinforced if the reanalysis considers
assumptions and modeling techniques for boundary conditions, cracking of
sections, and other conditions that would affect the dynamic behavior of
these walls. A periodic surveillance program to monitor any special con- ditions, such as the growth of existing cracks, was not specifically
required. The recurring nature of some of the observed cracks may justify
a periodic surveillance by licensees to ascertain that the level of structural
adequacy to which licensees committed is maintained.
B. During the field walkdown portion of the followup inspection conducted at
Calvert Cliffs, Units 1 and 2, on January 13-17, 1986, the inspectors
determined that two of the masonry walls included in the sample group had
boundary conditions deviating from those assumed in the reevaluation
analyses. There was relative motion between one wall (wall T) and the
ceiling beam and the mortar joint between the wall and the ceiling beam
appeared cracked for its entire length. At some points, this joint
contained voids that allowed probing of the interior of the wall. The
second wall (wall U) also showed evidence of cracking at the wall to
ceiling beam mortar joint.
The reanalysis assumed a simple support at the wall-to-ceiling beam
location for wall T and assumed a fixed support at this location for
wall U. However, the inspection team concluded that the actual boundary
conditions deviated from those assumed in the reanalyses for walls T
and U. The assumption of a positive connection between the wall and
the ceiling beam had been an important factor in the reevaluation
calculations for these two walls.
Attachment 1 IN 87-67 December 31, 1987 The licensee conducted a followup testing program and found that 5 of
the 11 walls included in the test sample did not contain rebar as
previously assumed.
C. In preparation for an NRC followup inspection to IE Bulletin 80-11 scheduled at Maine Yankee on March 10-14, 1986, the licensee con- ducted a new survey of masonry block walls. The survey identified 10
masonry walls that were classified as safety-related by the bulletin
definitions but had not been included in bulletin actions. Of the 10
walls, 5 had been in existence at the time of the licensee's original
survey (1980) and the remaining 5 walls had been added or reclassified
after the original survey. The inspectors determined that surveys were
not performed by controlled procedures and instructions and that this
omission contributed to the lack of complete coverage of the original
work.
D. During the followup inspection conducted at Oyster Creek on May 5-9, 1986, the licensee stated that approximately 200 masonry walls exist throughout
the plant and that 45 of these walls had been addressed by bulletin
responses. The licensee identified the walls that needed to be addressed
in response to the bulletin presumably by reviewing existing plant draw- ings and conducting an in-plant walkdown. However, the licensee could not
provide records to verify the adequacy of these activities. This lack of
documentation made it impossible for the inspectors to verify that the
licensee had correctly identified all the masonry walls specified by the
bulletin.
For the analysis, the licensee assumed that type M mortar had been used in
accordance with the original construction specification. However, no
documentation showed that type M mortar was used during construction. The
licensee had not developed a test program to demonstrate the strength
values of the mortar used, nor had the licensee considered lower strength
properties in the reanalysis.
The licensee is planning to resurvey the 200 masonry walls to reestablish
baseline data (e.g., physical dimensions, boundary conditions, and
attached equipment) that will be used for any future plant modifications
that might affect safety-related masonry walls. This data also will be
used to determine which masonry walls are categorized as safety-related.
The licensee is developing a procedure to control future modifications to
safety-related masonry walls. This procedure is intended to prevent the
alteration of any masonry wall such that the structural analysis would be
invalidated or, as an alternative, to provide for proper notification so
an engineering evaluation can be completed. The licensee will perform
periodic surveillance of masonry walls to ensure that the physical condi- tions assumed during the reanalysis effort remain valid.
Attachment 1 IN 87-67 December 31, 1987 During the NRC walkdown portion of the inspection, inspectors noted that
wall 22 had incurred a through-wall crack and that wall 23 had incurred a
similar crack. In addition, because of the location of equipment it could
not be determined whether the crack in wall 23 extended through the wall.
There were several other, less extensive cracks noted in these two walls.
Licensee actions to correct this problem include:
1. an analysis of the probable cause of the cracks
2. documentation of the repair efforts for these cracks or a demonstra- tion of the structural adequacy of the walls, including the effects
of the cracked block and mortar
3. a description of the measures to be taken to prevent recurrence of
similar cracking in these and other safety-related masonry walls that
are not reinforced
E. Similar deficiencies to those specified above were also identified during
the followup inspections to Bulletin 80-11 conducted at Yankee Rowe, Salem, Units 1 and 2, and Peach Bottom, Units 2 and 3. These NRC inspec- tions were conducted on January 26-30, 1987, April 7-10, 1987, and
June 15-19, 1987, respectively.
IN 87-67 December 31, 1987 No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
A. A. Varela
(215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection
Findings with Potential Safety Impact
2. List of Recently Issued NRC Information Notices
Per telephone conversation with Varela on 12/23/87, he indicated concurrence
by Strosneider and Varela.
Transmitted by memorandum to C. E. Rossi from J. R. Strosneider, Region I,
dated August 4, 1987.
- SEE PREVIOUS CONCURRENCES
12/ ZrM87
- OGCB:DOEA:NRR *D: DEST *1RI *PPMB:ARM *C/OGCB:DOEA:NRR
JGuillen LShao AlWarela TechEd CHBerlinger
12/3/87 12/29/87 2/23/87 11/24/87 12/11/87
rI
IN 87-XX
December xx, 1987 No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
A. A. Varela
(215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection
Findings with Potential Safety Impact
2. List of Recently Issued NRC Information Notices
Per telephone conversation with Varela on 12/23/87, he indicated concurrence
by Strosneider and Varela. cLo Eis .
Transmitted by memorandum to C. E. Rossi from J. R. Strosneider, Region I,
dated August 4, 1987.
- SEE PREVIOUS CONCURRENCES
D/DOEA:NRR
MCoD" os" CERossi
- C .e ww. 12/ /87
- OGCB:DOEA:NRF *RI *PPMB:ARP *C/OGCB:DOEA:NRR
JGuillen AAMarela TechEd CHBerlinger
12/3/87 12/A /87 12/23/87 11/24/87 12/11/87
- Only General Approach Reviewed - Specific Event Details Not Reviewed
IN 87-XX
December xx, 1987 No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
A. A. Varela
(215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection
Findings with Potential Safety Impact
2. List of Recently Issued NRC Information Notices
Transmitted by memorandum to C. E. Rossi from J. R. Strosneider, Region I,
dated August 4, 1987.
- SEE PREVIOUS CONCURRENCES
D/DOEA:NRR
CERossi
12/ /87 OG RR P B:D :ARES Rra *PPMB:ARM C/OGCB:DOEA:
JGuifenfi NCh hi AAVarela TechEd CHBerlinger 1 It?)
12/ Y 87 12/ /87 12/,b/87 11/24/87 12/J1/87 /V{
IN 87-XX
November xx, 1987 Page 2 of
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
A. A. Varela
(215) 337-5346 Attachments:
1. Examples of TE Bulletin 80-11 Inspection
Findings with Potential Safety Impact
2. List of Recently Issued NRC Information Notices
D/DOEA:NRR
CERossi
11/ /87 OGCB:DOEA:NRR PRA p :.-RES RI PPMB :ARt C/OGCB:DOEA:NRR
JGuillen NCh hi AAVarela Tech d CHBerlinger
11/ /87 117 /87 11/ /87 11 ; / 7 1I/ /87