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.i arles E.Ussi, 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
I Attachment
2 DIN 87-67 December 31, 1987 LIST OF RECENTLY ISSUED NRC INFORMATION
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
Appplication
12/31/87 of Commercial-Grade
Components
Air Systems Problems at 12/28/87 U.S. Light Water Reactors Plant Operation
Beyond 12/23/87 Analyzed Conditions
Conviction
for Falsification
1222/87 of Security Training Records Reactor Trip Breaker 12/16/87 Westinghouse
Nodel OS-416, Feaied to Open on Manuel Initiation
From the Control Room Inadequate
Net Positive 12/9/87 Suction Read in Low Pressure Safety Systems Mechanical
Failure of 12/B/87 Indicating-Type
Fuses Failure of Westinghouse
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of Reactor 32/4/87 Coolant Systems in PressuriZed-Water
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holding an OL or CP end all major fuel facility licensees.
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
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COMMISSION
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.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 by Strosneider
and Varela.Transmitted
by memorandum
to C.dated August 4, 1987.*SEE PREVIOUS CONCURRENCES
Varela on 12/23/87, he indicated
concurrence
E. Rossi from J. R. Strosneider, Region I, 12/ ZrM87 RI *PPMB:ARM
- C/OGCB:DOEA:NRR
Warela TechEd CHBerlinger
2/23/87 11/24/87 12/11/87*OGCB:DOEA:NRR
JGuillen 12/3/87*D: DEST LShao 12/29/87*1 Al
r I 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, by Strosneider
and Varela. cLo Eis .Transmitted
by memorandum
to C. E. Rossi from J. R.dated August 4, 1987.he indicated
concurrence
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
Safety Impact 2. List of Recently Issued NRC Information
Notices Transmitted
by memorandum
dated August 4, 1987.to C. E. Rossi from J. R. Strosneider, Region I,*SEE PREVIOUS CONCURRENCES
OG RR JGuifenfi 12/ Y 87 P B:D :ARES NCh hi 12/ /87 Rra AAVarela 12/,b/87 D/DOEA:NRR
CERossi 12/ /87 C/OGCB:DOEA:
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
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 OGCB: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 11/ /87 C/OGCB:DOEA:NRR
CHBerlinger
1I/ /87