ML17298B116
| ML17298B116 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/13/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML17298B117 | List: |
| References | |
| ANPP-29961-TDS, NUDOCS 8407300305 | |
| Download: ML17298B116 (14) | |
Text
1
~O Arizona Public Service Company AECBVED NAG lStIt', Ju'L 10 I"iI l: 05 July 13, 1984 ANPP-29961-TDS/TRB AEGMNO'I8F U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane Suite 210 Walnut Creek, CA 94596-5368 Attention: Mr. T.
W. Bishop, Director Division of Resident Reactor Projects and Engineering Programs Sub)ect:
Request For Information Concerning Design Review By C-E And Acceptance Criteria For The Reactor Vessel Lower Support Shim Clearance File'.
84-019-026; D.4.33.2
Reference:
NRC's Letter From T.
W. Bishop To E. E. Van Brunt, Jr.,
dated June 8, 1984 This letter is in response to the request for additional information transmitted in the referenced letter.
Our response is contained in Attachment A and B, respectively.
Very truly yours, nul 8407300305 8407i3 PDR ADOCK 05000528
'DR t'
E.
E. Van Brunt, Jr.
APS Vice President Nuclear Production ANPP Project Director EEVB/TRB:db CC ~
See Page Two
l I
j t
I J
I I
cc~
Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 T. G. Woods, Jr.
D. B. Earner W. E. Ide D.
B. Fasnacht A. C. Rogers L. A.
Sou@a D'. Fowler T. D. Shriver C. N. Russo J. Vorees J.
R.
Bynum J.
M. Allen J. A. Brand A. C. Gehr W. J. Stubblefield W. G. Bingham R. L. Patterson R.
W. Welcher H. D. Foster D. R. Hawkinson L. E. Vorderbrueggen R. P.
Zimmerman S. R. Frost J. Self D. Canady T. J.
Bloom Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500
- Atlanta, GA 30339
t I
~
~
~
~
J
~
L I
July 13, 1984 ATTACHMENT A RE UEST FOR INFORMATION CONCERNING DESIGN REVIEW BY C-E The C-E Site Office participates as a voting member of both Test Working Group (TWG) and Test Results Review Group (TRRG).
These bodies review original issued procedures and any subsequent changes/revisions to them.
A question has been posed as to the method for providing auditability of the Windsor Engineering involvement in these reviews.
Guidelines have been developed to assist the Site engineer in determining when Windsor engineering review is required.
The guidelines, attached for your review, are basically restricted to the C-E scope of supply.
The attached guidelines are used when issues which arise in the review cannot be resolved by the C-E Site representative.
These issues are sent to Windsor engineering via the Project Office, using the form attached or, if more appropriate, an Engineering Evaluation Request (EER)
[APS generated]
or a Field Action Request (FAR) [C-E generated].
The method of informing Windsor is left to the judgement of the Site engineer.
When answering a request, Windsor engineering will, as appropriate, issue a
- letter, a drawing change, specification
- change, or other updated document.
If the procedure revision is to a safety-related item, C-E Engineering will document the revision in accordance with the C-E gA program.
I
ATTACHMENT A (Continued)
Page Two C-E PROCEDURES REVIEW GUIDELINES To insure consistency and proper documentation, the following guidelines have been developed.
These guidelines will be used by the site office to determine when C-E Windsor engineering review is needed.
If an EER or FAR is generated it will be sent to the project office (with a copy of the procedure, if necessary).
The pro.ject office will then be responsible for further determination of the requirement for C-E Windsor review, and, if the review is necessary, for the coordination of the C-E Windsor review. If it is necessary to consult with Windsor Engineering and an EER or FAR is not generated, then Windsor Engineering's input should be documented with a telecon.
Any YES answers to the questions below require C-E Windsor engineering to review at least the affected portion of the test.
A.
Objectives 1.
Have the original test objectives supplied by C-E been deletedf NOTE:
The test scope may be expanded by APS to included additional tests which APS may require.
APS may rearrange testing to optimize the test sequence.
B.
Acceptance Criteria 1.
Have the C-E supplied Acceptance Criteria been modifiedg NOTE: If the C-E supplied Acceptance Criteria are intact, C-E Windsor review is not required. If additional test objectives were added by APS, new Acceptance Criteria may be added to the procedure.
These types of procedure changes will not be submitted to C-E Windsor for review unless C-E review is requested by APS.
All added Acceptance Criteria for new APS test objectives must be consistent with C-E supplied Acceptance Criteria or C-E Windsor engineering review will be required.
C.
Pre-requisites 1.
Do the modifications to the prerequisites compromise the test method in meeting the test objectives'otes:
(1)
APS may add or delete administrative prerequisites without C-E Windsor approval; (2)
APS may add new prerequisites which are needed to meet the APS added test objectives without C-E Windsor approval.
~
~
e
~l>>
8 pl
~
ATTACHMENT A (continued)
Page Three D.
Initial Conditions 1.
Do the initial condition changes substantially affect the test data qualityP 2.
Do the initial condition changes substantially impact the ability of the test to meet the test obgectivesP E.
Detailed Procedure 1.
Do the changes to the test steps or test sequence modify the original intent of the test methods 2.
Do the changes to the procedure make it difficult to evaluate the success of the test in meeting the Acceptance CriteriaP F.
Appendices 1.
Does the procedure modification delete essential data needed to calculate the test value that is compared to the Acceptance Criteriat
- 2. Does the procedure modification change the calculation method so the test value that is calculated does not correlate with test requirement documentsP
~
~
ATTACHMENT A (Continued)
Page Pour C-E SITE OFFICE PROCEDURE EVALUATION Date.'rocedure
Title:
Procedure Number:
LPPT Rev.:
Preop C-E Scope Yes/No NUREG 0694 Yes/No Procedure or Procedure Revision.')
retains objectives and acceptance criteria b) retains teat, data collection and calculational methods c) retains original test equipment d) is consistent with Regulatory Guides e) is consistent with CESSAR/FSAR (including Technical Specifications and Special Teat Exceptions Yes/No/NA Yes/No/NA Yes/No/NA Yes/No/NA Yes/No/NA f) is consistent with C-E Operating Guidelines g) does not introduce new safety issues and/or system conditions which may impact plant safety Yes/No/NA Yes/No/NA Summary of Changes(s):
Office Recommendation:
Resolution:
Site Manager:
Date:
C-E:
Date:
~
~
s
~
y4,e g
1 J
~
ATTACHMENT B ADDITIONAL INFORMATION REGARDING TECHNICAL CONCERNS IN CONNECTION WITH REACTOR VESSEL SHIMMING REQUIREMENTS Hot Functional Testing was performed without the lower shim assemblies as specified in the approved test procedure.
C-E concurred that pre-core HPT could be be conducted without installation of either temporary or permanent lower RV support shims and crush pads.
In C-E's concurrence to conduct pre-core HPT without installation of lower RV support shims and crush pads, C-E required that sufficient meas-urements be taken to properly size the lower expansion plate shims and that verification of final installation will be required during post-core HPT.
The required measurements were taken during pre-core HFT.
C-E confirmed that the lower reactor vessel support shims and crush pads are required only during a seismic event, and that any rotation and/or thermal displacement of the reactor vessel would have been inhibited by the installed permanent upper support shims.
Based on this information the lower reactor vessel keys were not monitored for any movement in ex-cess of the.035" +.015" that would have been possible if the shim and crush pads would have been installed.
The C-E Drawing (E-14273-321-101, Revision 3) requirement of a measured hot gap of.035" +.015" is the centrali,zed system equipment for the reactor vessel support gaps, both upper and lower.
The acceptance criteria of 0.030 minimum sum of corresponding side gaps was chosen to assure no binding of the reactor vessel supports recognizing that shims can be re-set after pre-core HPT is completed and verified during post-core HPT.
C-E has reviewed all the provided HFT data and found them to be acceptable.
r P'
"II'