Information Notice 1987-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11: Difference between revisions

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{{#Wiki_filter:IN 87-67 UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:IN 87-67 UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


===OFFICE OF NUCLEAR REACTOR REGULATION===
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555 -December 31, 1987 NRC INFORMATION


NOTICE NO. 87-67: LESSONS LEARNED FROM REGIONAL INSPECTIONS
WASHINGTON, D.C. 20555        -
                                December 31, 1987 NRC INFORMATION NOTICE NO. 87-67:   LESSONS LEARNED FROM REGIONAL


OF LICENSEE ACTIONS IN RESPONSE TO IE BULLETIN 80-11  
INSPECTIONS OF LICENSEE ACTIONS IN
 
RESPONSE TO IE BULLETIN 80-11


==Addressees==
==Addressees==
:
:
All holders of operating
All holders of operating licenses or construction permits for nuclear power
 
licenses or construction


permits for nuclear power reactors.
reactors.


==Purpose==
==Purpose==
: This information
:
This information notice is being provided to inform addressees of lessons


notice is being provided to inform addressees
learned from Nuclear Regulatory Commission (NRC) inspections of certain activi- ties related to the reevaluation work conducted and plant modifications made in


of lessons learned from Nuclear Regulatory
response to Bulletin 80-11, Masonry Wall Design, issued on May 8, 1980. It is


Commission (NRC) inspections
expected that recipients will review the information for applicability to their


of certain activi-ties related to the reevaluation
facilities and consider actions, as appropriate, to avoid similar problems.


work conducted
However, suggestions contained in this information notice do not constitute


and plant modifications
NRC requirements; therefore, no specific action or written response is required.


made in response to Bulletin 80-11, Masonry Wall Design, issued on May 8, 1980. It is expected that recipients
==Description of Circumstances==
 
:
will review the information
IE Bulletin 80-11, Masonry Wall Design, addressed the potential for problems
 
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
with the structural adequacy of concrete masonry walls in proximity to or with


for affecting
attachments to safety-related piping or equipment. In brief, all licensees


plant safety. Some of the types of deficiencies
for operating nuclear power reactor facilities were required to:
1.   identify all masonry walls in each facility that are located in proximity


discovered
to or have attachments to safety-related piping or equipment


are described
2.    provide a reevaluation of the design adequacy of the subject walls


below; specific examples are discussed in Attachment
3.    provide written reports of the activities required by the bulletin


1.8100 ' 10fs-/
While performing inspections to follow up on IE Bulletin 80-11 activities at
IN 87-67 December 31, 1987 Unanalyzed


Conditions
several plants, NRC inspectors and consultant personnel noted several defi- ciencies having the potential for affecting plant safety. Some of the types


Unreinforced
of deficiencies discovered are described below; specific examples are discussed


masonry walls were discovered
in Attachment 1.


to contain cracks that were not accounted
8100                                  '                                  10fs-/


for in the structural
IN 87-67 December 31, 1987 Unanalyzed Conditions


analyses of the walls. This situation
Unreinforced masonry walls were discovered to contain cracks that were not


was found at several plants and ranged from mortar joint cracks to through-wall
accounted for in the structural analyses of the walls. This situation was


cr~acks in block and mortar. These conditions
found at several plants and ranged from mortar joint cracks to through-wall


required remedial action by licensees
cr~acks in block and mortar. These conditions required remedial action by


after the cracks were discovered.
licensees after the cracks were discovered.


===Improper Assumptions===
===Improper Assumptions===
Several instances
Several instances were found in different facilities where assumptions made
 
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
during the reevaluation analyses for individual walls were either in error or


had been reclassified
had not been verified. Items in question included unsubstantiated mortar


as safety-related
properties, faulty assumptions for wall boundary conditions, and assumed


after the initial IE Bulletin 80-11 work had been completed.
reinforcement that had not been verified. In each case, remedial action was


===However, the reclassified===
required by the licensee.
walls were not reevaluated


to verify that the bulletin requirements
===Improper Classification===
Classification of masonry walls as safety-related and not safety-related was


were met.Lack of Procedural
also found to be a problem. At one site, it was discovered that five walls


Controls Several cases were identified
that were not safety-related had been reclassified as safety-related after the


at different
initial IE Bulletin 80-11 work had been completed. However, the reclassified


facilities
walls were not reevaluated to verify that the bulletin requirements were met.


where activities
===Lack of Procedural Controls===
Several cases were identified at different facilities where activities were


were performed
performed on safety-related components or equipment without proper controls.


on safety-related
These activities included the performance of walkdown surveys, record keeping, and the control of modification activities.
 
components
 
or equipment
 
without proper controls.These activities
 
included the performance
 
of walkdown surveys, record keeping, and the control of modification
 
activities.


Discussion
Discussion


The deficiencies
The deficiencies regarding unanalyzed conditions and faulty assumptions high- light the need for careful field verification of all critical parameters used
 
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
in the qualification by analysis of masonry walls. Use of carefully written


to ensure that the physical conditions
and approved procedures would have helped to prevent overlooking walls subject


of masonry walls remained as previously
to bulletin action during the original surveys. Written procedures governing


analyzed.
reclassification of or modification to the subject walls would have helped to


Some licensees
prevent the failure to evaluate the reclassified or newly installed walls to


have developed
the bulletin requirements.


programs with procedural
NRC inspectors observed that mechanisms did not exist at certain facilities to


controls requiring
ensure that the physical conditions of masonry walls remained as previously


engineering
analyzed. Some licensees have developed programs with procedural controls


notification, reevaluation, and periodic inspections
requiring engineering notification, reevaluation, and periodic inspections to


to ensure that the structural
ensure that the structural integrity of these walls is maintained. These


integrity
programs ensure that the physical condition of the walls, such as lack of


of these walls is maintained.
mortar cracking and boundary conditions, remain as analyzed.


These programs ensure that the physical condition
IN 87-67 December 31, 1987 No specific action or written response is required by this information notice.


of the walls, such as lack of mortar cracking and boundary conditions, remain as analyzed.
If you have any questions about this matter, please contact the technical


IN 87-67 December 31, 1987 No specific action or written response is required by this information
contact listed below or the Regional Administrator of the appropriate regional


notice.If you have any questions
office.


about this matter, please contact the technical contact listed below or the Regional Administrator
iDivision


of the appropriate
arles E.Ussi, Director


regional office.i arles E.Ussi, Director Division of Operational
of Operational Events Assessment


===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
===Technical Contact:===


Contact: A. A. Varela (215) 337-5346 Attachments:
===A. A. Varela===
                    (215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection
1. Examples of IE Bulletin 80-11 Inspection


Findings with Potential
Findings with Potential Safety Impact


Safety Impact 2. List of Recently Issued NRC Information
2. List of Recently Issued NRC Information Notices


Notices
I  Attachment 2 DIN87-67 December 31, 1987 LIST OFRECENTLY ISSUED


I Attachment
NRC INFORMATION NOTICES 1987 In formation                                    M&lW oT


2 DIN 87-67 December 31, 1987 LIST OF RECENTLY ISSUED NRC INFORMATION
Notice No.      Sublect                        Issuance    Issued to


NOTICES 1987 In formation Notice No.87-66 87-28.Supp. 1 87-65 87-64 87-35.Supp. 1 87-63 87-62 87-61 87-60 Sublect M&lW oT Issuance Inappropriate
87-66           Inappropriate Appplication    12/31/87   All holders of OLs


Appplication
of Commercial-Grade                        or CPs for nuclear


12/31/87 of Commercial-Grade
Components                                power reactors.


Components
87-28.          Air Systems Problems at        12/28/87    All holders of OLs


Air Systems Problems at 12/28/87 U.S. Light Water Reactors Plant Operation
Supp. 1        U.S. Light Water Reactors                 or CPs for nucletr


Beyond 12/23/87 Analyzed Conditions
power reactors.


Conviction
87-65          Plant Operation Beyond          12/23/87    All holders of OLs


for Falsification
Analyzed Conditions                        or CPs for nuclear


1222/87 of Security Training Records Reactor Trip Breaker 12/16/87 Westinghouse
power reactors.


Nodel OS-416, Feaied to Open on Manuel Initiation
87-64          Conviction for Falsification 1222/87      All nuclear power


From the Control Room Inadequate
of Security Training Records                reactor facilities


Net Positive 12/9/87 Suction Read in Low Pressure Safety Systems Mechanical
holding an OL or CP


Failure of 12/B/87 Indicating-Type
end all major fuel


Fuses Failure of Westinghouse
facility licensees.


12/7/87 W-2-TYPe Circuit Breaker Cell Switches.Oepressurization
87-35.          Reactor Trip Breaker          12/16/87   All holders of OLs


of Reactor 32/4/87 Coolant Systems in PressuriZed-Water
Supp. 1        Westinghouse Nodel OS-416,                or CPs for nuclear


Reactors Issued to All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nucletr power reactors.All holders of OLs or CPs for nuclear power reactors.All nuclear power reactor facilities
Feaied to Open on Manuel                  power reactors.


holding an OL or CP end all major fuel facility licensees.
Initiation From the Control


All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for PWRs.OL
Room


* Operating
87-63          Inadequate Net Positive        12/9/87    All holders of OLs


License CP
Suction Read in Low Pressure                or CPs for nuclear


* Construction
Safety Systems                            power reactors.


Permit UNITED STATES NUCLEAR REGULATORY
87-62          Mechanical Failure of          12/B/87    All holders of OLs


COMMISSION
Indicating-Type Fuses                      or CPs for nuclear


WASHINGTON, D.C. 20555 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 FIRST CLAS MAIL POSTAGE t FEES PAID USSNRC PERMIT No. 07
power reactors.
.I * .Attachment


1 IN 87-67 December 31, 1987 EXAMPLES OF IE BULLETIN 80-11 INSPECTION
87-61          Failure of Westinghouse        12/7/87    All holders of OLs


FINDINGS WITH POTENTIAL
W-2-TYPe Circuit Breaker                  or CPs for nuclear


SAFETY IMPACT Specific examples of some of the deficiencies
Cell Switches.                            power reactors.


discovered
87-60          Oepressurization of Reactor    32/4/87    All holders of OLs


during the inspections
Coolant Systems in                        or CPs for PWRs.


performed
PressuriZed-Water Reactors


to follow up on IE Bulletin 80-11 activities
OL


and licensee actions to correct the problems are discussed
* Operating License


below.A. During an inspection
CP


conducted
* Construction Permit


at Indian Point, Unit 2, on September
UNITED STATES


16-20, 1985, the NRC inspectors
NUCLEAR REGULATORY COMMISSION                                                                                    FIRST CLAS MAIL


observed mortar joint cracking in the west and south walls of the fan house. The licensee proposed an appropriate
POSTAGE t FEES PAID


repair procedure
WASHINGTON, D.C. 20555                                                                                          USSNRC


to fix these cracks. This approach was accepted by the NRC as part of the licensee's
PERMIT No. 07 OFFICIAL BUSINESS


proposed modifications.
PENALTY FOR PRIVATE USE, $300


Inspectors
. I  * .


observed evidence of repair activities
Attachment 1 IN 87-67 December 31, 1987 EXAMPLES OF IE BULLETIN 80-11 INSPECTION FINDINGS


during the onsite field walkdown conducted
WITH POTENTIAL SAFETY IMPACT


as part of the followup inspection.
Specific examples of some of the deficiencies discovered during the inspections


However, they also observed the presence of numerous mortar joint cracks, some of which were in joints that appeared to have been previously
performed to follow up on IE Bulletin 80-11 activities and licensee actions to


repaired.The NRC reevaluation
correct the problems are discussed below.


acceptance
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


criteria includes a provision
of the fan house. The licensee proposed an appropriate repair procedure to


for allowing tension in masonry walls that are not reinforced
fix these cracks. This approach was accepted by the NRC as part of the


if the reanalysis
licensee's proposed modifications. Inspectors observed evidence of repair


considers assumptions
activities during the onsite field walkdown conducted as part of the followup


and modeling techniques
inspection. However, they also observed the presence of numerous mortar


for boundary conditions, cracking of sections, and other conditions
joint cracks, some of which were in joints that appeared to have been


that would affect the dynamic behavior of these walls. A periodic surveillance
previously repaired.


program to monitor any special con-ditions, such as the growth of existing cracks, was not specifically
The NRC reevaluation acceptance criteria includes a provision for allowing


required.
tension in masonry walls that are not reinforced if the reanalysis considers


The recurring
assumptions and modeling techniques for boundary conditions, cracking of


nature of some of the observed cracks may justify a periodic surveillance
sections, and other conditions that would affect the dynamic behavior of


by licensees
these walls. A periodic surveillance program to monitor any special con- ditions, such as the growth of existing cracks, was not specifically


to ascertain
required. The recurring nature of some of the observed cracks may justify


that the level of structural
a periodic surveillance by licensees to ascertain that the level of structural


adequacy to which licensees
adequacy to which licensees committed is maintained.


committed
B.  During the field walkdown portion of the followup inspection conducted at


is maintained.
Calvert Cliffs, Units 1 and 2, on January 13-17, 1986, the inspectors


B. During the field walkdown portion of the followup inspection
determined that two of the masonry walls included in the sample group had


conducted
boundary conditions deviating from those assumed in the reevaluation


at Calvert Cliffs, Units 1 and 2, on January 13-17, 1986, the inspectors
analyses. There was relative motion between one wall (wall T) and the


determined
ceiling beam and the mortar joint between the wall and the ceiling beam


that two of the masonry walls included in the sample group had boundary conditions
appeared cracked for its entire length. At some points, this joint


deviating
contained voids that allowed probing of the interior of the wall. The


from those assumed in the reevaluation
second wall (wall U) also showed evidence of cracking at the wall to


analyses.
ceiling beam mortar joint.


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
The reanalysis assumed a simple support at the wall-to-ceiling beam


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
location for wall T and assumed a fixed support at this location for


assumed a simple support at the wall-to-ceiling
wall U. However, the inspection team concluded that the actual boundary


beam location for wall T and assumed a fixed support at this location for wall U. However, the inspection
conditions deviated from those assumed in the reanalyses for walls T


team concluded
and U. The assumption of a positive connection between the wall and


that the actual boundary conditions
the ceiling beam had been an important factor in the reevaluation


deviated from those assumed in the reanalyses
calculations for these two walls.


for walls T and U. The assumption
Attachment 1 IN 87-67 December 31, 1987 The licensee conducted a followup testing program and found that 5 of


of a positive connection
the 11 walls included in the test sample did not contain rebar as


between the wall and the ceiling beam had been an important
previously assumed.


factor in the reevaluation
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


calculations
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


for these two walls.
survey (1980) and the remaining 5 walls had been added or reclassified


Attachment
after the original survey. The inspectors determined that surveys were


1 IN 87-67 December 31, 1987 The licensee conducted
not performed by controlled procedures and instructions and that this


a followup testing program and found that 5 of the 11 walls included in the test sample did not contain rebar as previously
omission contributed to the lack of complete coverage of the original


assumed.C. In preparation
work.


for an NRC followup inspection
D. During the followup inspection conducted at Oyster Creek on May 5-9, 1986, the licensee stated that approximately 200 masonry walls exist throughout


to IE Bulletin 80-11 scheduled
the plant and that 45 of these walls had been addressed by bulletin


at Maine Yankee on March 10-14, 1986, the licensee con-ducted a new survey of masonry block walls. The survey identified
responses. The licensee identified the walls that needed to be addressed


10 masonry walls that were classified
in response to the bulletin presumably by reviewing existing plant draw- ings and conducting an in-plant walkdown. However, the licensee could not


as safety-related
provide records to verify the adequacy of these activities. This lack of


by the bulletin definitions
documentation made it impossible for the inspectors to verify that the


but had not been included in bulletin actions. Of the 10 walls, 5 had been in existence
licensee had correctly identified all the masonry walls specified by the


at the time of the licensee's
bulletin.


original survey (1980) and the remaining
For the analysis, the licensee assumed that type M mortar had been used in


5 walls had been added or reclassified
accordance with the original construction specification. However, no


after the original survey. The inspectors
documentation showed that type M mortar was used during construction. The


determined
licensee had not developed a test program to demonstrate the strength


that surveys were not performed
values of the mortar used, nor had the licensee considered lower strength


by controlled
properties in the reanalysis.


procedures
The licensee is planning to resurvey the 200 masonry walls to reestablish


and instructions
baseline data (e.g., physical dimensions, boundary conditions, and


and that this omission contributed
attached equipment) that will be used for any future plant modifications


to the lack of complete coverage of the original work.D. During the followup inspection
that might affect safety-related masonry walls. This data also will be


conducted
used to determine which masonry walls are categorized as safety-related.


at Oyster Creek on May 5-9, 1986, the licensee stated that approximately
The licensee is developing a procedure to control future modifications to


200 masonry walls exist throughout
safety-related masonry walls. This procedure is intended to prevent the


the plant and that 45 of these walls had been addressed
alteration of any masonry wall such that the structural analysis would be


by bulletin responses.
invalidated or, as an alternative, to provide for proper notification so


The licensee identified
an engineering evaluation can be completed. The licensee will perform


the walls that needed to be addressed in response to the bulletin presumably
periodic surveillance of masonry walls to ensure that the physical condi- tions assumed during the reanalysis effort remain valid.


by reviewing
Attachment 1 IN 87-67 December 31, 1987 During the NRC walkdown portion of the inspection, inspectors noted that


existing plant draw-ings and conducting
wall 22 had incurred a through-wall crack and that wall 23 had incurred a


an in-plant walkdown.
similar crack. In addition, because of the location of equipment it could


However, the licensee could not provide records to verify the adequacy of these activities.
not be determined whether the crack in wall 23 extended through the wall.


This lack of documentation
There were several other, less extensive cracks noted in these two walls.


made it impossible
Licensee actions to correct this problem include:
  1.  an analysis of the probable cause of the cracks


for the inspectors
2.  documentation of the repair efforts for these cracks or a demonstra- tion of the structural adequacy of the walls, including the effects


to verify that the licensee had correctly
of the cracked block and mortar


identified
3.  a description of the measures to be taken to prevent recurrence of


all the masonry walls specified
similar cracking in these and other safety-related masonry walls that


by the bulletin.For the analysis, the licensee assumed that type M mortar had been used in accordance
are not reinforced


with the original construction
E. Similar deficiencies to those specified above were also identified during


specification.
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


However, no documentation
June 15-19, 1987, respectively.


showed that type M mortar was used during construction.
IN 87-67 December 31, 1987 No specific action or written response is required by this information notice.


The licensee had not developed
If you have any questions about this matter, please contact the technical


a test program to demonstrate
contact listed below or the Regional Administrator of the appropriate regional


the strength values of the mortar used, nor had the licensee considered
office.


lower strength properties
Charles E. Rossi, Director


in the reanalysis.
Division of Operational Events Assessment


The licensee is planning to resurvey the 200 masonry walls to reestablish
Office of Nuclear Reactor Regulation


baseline data (e.g., physical dimensions, boundary conditions, and attached equipment)
===Technical Contact:===
that will be used for any future plant modifications


that might affect safety-related
===A. A. Varela===
 
                      (215) 337-5346 Attachments:
masonry walls. This data also will be used to determine
1. Examples of IE Bulletin 80-11 Inspection
 
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
Findings with Potential Safety Impact


the effects of the cracked block and mortar 3. a description
2. List of Recently Issued NRC Information Notices


of the measures to be taken to prevent recurrence
Per telephone conversation with Varela on 12/23/87, he indicated concurrence


of similar cracking in these and other safety-related
by Strosneider and Varela.


masonry walls that are not reinforced
Transmitted by memorandum to C. E. Rossi from J. R. Strosneider, Region I,
dated August 4, 1987.


E. Similar deficiencies
*SEE PREVIOUS CONCURRENCES


to those specified
12/ ZrM87
*OGCB:DOEA:NRR *D: DEST        *1RI      *PPMB:ARM      *C/OGCB:DOEA:NRR


above were also identified
JGuillen        LShao          AlWarela TechEd          CHBerlinger


during the followup inspections
12/3/87        12/29/87          2/23/87 11/24/87        12/11/87


to Bulletin 80-11 conducted
rI


at Yankee Rowe, Salem, Units 1 and 2, and Peach Bottom, Units 2 and 3. These NRC inspec-tions were conducted
IN 87-XX


on January 26-30, 1987, April 7-10, 1987, and June 15-19, 1987, respectively.
December xx, 1987 No specific action or written response is required by this information notice.


IN 87-67 December 31, 1987 No specific action or written response is required by this information
If you have any questions about this matter, please contact the technical


notice.If you have any questions
contact listed below or the Regional Administrator of the appropriate regional


about this matter, please contact the technical contact listed below or the Regional Administrator
office.


of the appropriate
Charles E. Rossi, Director


regional office.Charles E. Rossi, Director Division of Operational
Division of Operational Events Assessment


===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
===Technical Contact:===
 
Contact: A. A. Varela (215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection


Findings with Potential
===A. A. Varela===
                          (215) 337-5346 Attachments:
    1. Examples of IE Bulletin 80-11 Inspection


Safety Impact 2. List of Recently Issued NRC Information
Findings with Potential Safety Impact


Notices Per telephone
2. List of Recently Issued NRC Information Notices


conversation
Per telephone conversation with Varela on 12/23/87, he indicated concurrence


with by Strosneider
by Strosneider and Varela. cLo Eis .


and Varela.Transmitted
Transmitted by memorandum to C. E. Rossi from J. R. Strosneider, Region I,
  dated August 4, 1987.


by memorandum
*SEE PREVIOUS CONCURRENCES


to C.dated August 4, 1987.*SEE PREVIOUS CONCURRENCES
D/DOEA:NRR


Varela on 12/23/87, he indicated
MCoD" os"                                CERossi


concurrence
**              C  .e ww.                  12/ /87
  *OGCB:DOEA:NRF                  *RI        *PPMB:ARP      *C/OGCB:DOEA:NRR


E. Rossi from J. R. Strosneider, Region I, 12/ ZrM87 RI *PPMB:ARM
JGuillen                        AAMarela  TechEd          CHBerlinger


*C/OGCB:DOEA:NRR
12/3/87          12/A /87        12/23/87  11/24/87      12/11/87
                    **  Only General Approach Reviewed - Specific Event Details Not Reviewed


===Warela TechEd CHBerlinger===
IN 87-XX
2/23/87 11/24/87 12/11/87*OGCB:DOEA:NRR


JGuillen 12/3/87*D: DEST LShao 12/29/87*1 Al
December xx, 1987 No specific action or written response is required by this information notice.


r I IN 87-XX December xx, 1987 No specific action or written response is required by this information
If you have any questions about this matter, please contact the technical


notice.If you have any questions
contact listed below or the Regional Administrator of the appropriate regional


about this matter, please contact the technical contact listed below or the Regional Administrator
office.


of the appropriate
Charles E. Rossi, Director


regional office.Charles E. Rossi, Director Division of Operational
Division of Operational Events Assessment


===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
===Technical Contact:===


Contact: A. A. Varela (215) 337-5346 Attachments:
===A. A. Varela===
                      (215) 337-5346 Attachments:
1. Examples of IE Bulletin 80-11 Inspection
1. Examples of IE Bulletin 80-11 Inspection


Findings with Potential
Findings with Potential Safety Impact
 
Safety Impact 2. List of Recently Issued NRC Information
 
Notices Per telephone
 
conversation
 
with Varela on 12/23/87, by Strosneider
 
and Varela. cLo Eis .Transmitted
 
by memorandum


to C. E. Rossi from J. R.dated August 4, 1987.he indicated
2. List of Recently Issued NRC Information Notices


concurrence
Transmitted by memorandum to C. E. Rossi from J. R. Strosneider, Region I,
 
dated August 4, 1987.
Strosneider, Region I,*SEE PREVIOUS*OGCB:DOEA:NRF
 
JGuillen 12/3/87 CONCURRENCES
 
MCoD " os" C .e ww.**D/DOEA:NRR
 
CERossi 12/ /87*C/OGCB:DOEA:NRR
 
CHBerlinger
 
*RI AAMarela*PPMB:ARP TechEd 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
*SEE PREVIOUS CONCURRENCES


Safety Impact 2. List of Recently Issued NRC Information
D/DOEA:NRR


Notices Transmitted
CERossi


by memorandum
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{


dated August 4, 1987.to C. E. Rossi from J. R. Strosneider, Region I,*SEE PREVIOUS CONCURRENCES
IN 87-XX


OG RR JGuifenfi 12/ Y 87 P B:D :ARES NCh hi 12/ /87 Rra AAVarela 12/,b/87 D/DOEA:NRR
November xx, 1987 Page 2 of


CERossi 12/ /87 C/OGCB:DOEA:
No specific action or written response is required by this information notice.
CHBerlinger


1 It?)12/J1/87 /V{*PPMB:ARM TechEd 11/24/87 IN 87-XX November xx, 1987 Page 2 of No specific action or written response is required by this information
If you have any questions about this matter, please contact the technical


notice.If you have any questions
contact listed below or the Regional Administrator of the appropriate regional


about this matter, please contact the technical contact listed below or the Regional Administrator
office.


of the appropriate
Charles E. Rossi, Director


regional office.Charles E. Rossi, Director Division of Operational
Division of Operational Events Assessment


===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
===Technical Contact:===


Contact: A. A. Varela (215) 337-5346 Attachments:
===A. A. Varela===
                      (215) 337-5346 Attachments:
1. Examples of TE Bulletin 80-11 Inspection
1. Examples of TE Bulletin 80-11 Inspection


Findings with Potential
Findings with Potential Safety Impact


Safety Impact 2. List of Recently Issued NRC Information
2. List of Recently Issued NRC Information Notices


Notices OGCB:DOEA:NRR
D/DOEA:NRR


JGuillen 11/ /87 PRA p :.- RES NCh hi 117 /87 RI AAVarela 11/ /87 PPMB :ARt Tech d 11 ; / 7 D/DOEA:NRR
CERossi


CERossi 11/ /87 C/OGCB:DOEA:NRR
11/ /87 OGCB:DOEA:NRR    PRA p :.-RES  RI        PPMB :ARt      C/OGCB:DOEA:NRR


CHBerlinger
JGuillen        NCh  hi      AAVarela  Tech d        CHBerlinger


1I/ /87}}
11/  /87        117 /87        11/  /87  11 ; / 7      1I/ /87}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Revision as of 02:56, 24 November 2019

Lessons Learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11
ML031140355
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane
Issue date: 12/31/1987
From: Rossi C
Office of Nuclear Reactor Regulation
To:
References
BL-80-011 IN-87-067, NUDOCS 8712300091
Download: ML031140355 (11)
v • d • e


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

holding an OL or CP

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

OL

  • Operating License

CP

  • 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


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