ML19260D558

Deficiency Rept Re Discrepancies in ASME Code Sys.Cause Unstated.Valves Will Be Replaced or Upgraded to Class 2 by Obtaining Proper Documentation from Manufacturer

ML19260D558
Person / Time
Site:	Farley
Issue date:	01/11/1980
From:	ALABAMA POWER CO.
To:
Shared Package
ML19260D555	List: ML19260D554 ML19260D558
References
NUDOCS 8002110412
Download: ML19260D558 (4)

Text

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CLASS 3 M LVES IN CLASS 2 SYSTEMS M.tial Report to NRC:

- Verbal report to Mr. M. D. Hunt (NRC, Region II) by Mr. W. C. Petty, Jr. (APCo QA Department) on November 7, 1979.

Description of Occurrence: During the qual'ty assurance traveler review of the Farley Unit 2 ASME code systems six discrepancies have been found. A total of 67% of the ASME systems have been reviewed.

Background:

To meet ASME Code Class 2 requirements, cast pressure-retaining materials are examined by either radiographic or ultrasonic methods, or a combination of the two methods. This is not a requirement for Class 3 materials and constitutes the difference between Class 2 and Class 3 valves. The Class 3 valves have the same pressure-retainino classification as the specified Class 2 valves. In all cases, the Class 3 valves were located at or near class boundary changes.

The valves involved in this analysis were:

Drawing Rev. Location Valve System NCR No.

D205039, Sheet 4 0 E6 E21V304 CVCS Q-2-M773 2/12/79 0205039, Sheet 2 0 H8 E21V210 CVCS Q-2-M779 2/12/79 D205039, Sheet 2 6 D10 E21V381B CVCS Q-2-M757 2/12/79 D205038, Sheet 3 0 C6 E13V007A Cont. Spray Q-2-M815 9/6/79 D205038, Sheet 3 0 F6 E13V007B Cont. Spray Q-2-M815 9/6/79 D205038, Sheet 1 4 B12 P44V505 High Head Q-2-M576 2/12/79 Safety Inj.

Using the above differences between a Class 2 and Class 3 valve, it was hypothesized that the existence of a defect in a Class 3 valve body could, at some time, result in the failure of the valve body, through crack propagation or similar fracture mechanism. The systems were analyzed assuming the valve body failed. This is analogous to a pipe break.

.n4 1 1 r 7, Analysis of Safety Imolications: ' ' ' '

i e A break in the body of valve E21V3818 and/or valve P44V505 was assumed. Analysis of the system reveals there are level detecters on the Volume Control Tank and the 8002210 I2'

Refueling Water Storage Tarik to detect the break. Since the lines are 3/4" lines, ar.y break would not result in immediate run-out of the tank. The valves were not considered to constitute either a significant deficiency or a substantial safety hazard since the leaks could be detected and repaired. Also, additional make-up can be pumped into the tanks.

An assumed break in the bodies of valves E13V007A and/or E13V007B could result in an increase in the iodine concentration withic containment since sodium hydroxide could not be placed into the containment spray sysi.em through the eductors in the unlikely event of needing containment sprays. This pcstulated event could cause a rise in iodine concentration above that calculated in Section 15 of the FSAR.

' An assumed break in the body of valve E21V210 could result in loss of water from the Volume Control Tank and/or the Refueling Water Storage Tank. As a result of the loss of water the charging pumps might not receive enough water and could possibly fail. Alabama Power Company has been infont.ed by the valva vendor that the valve has sufficient quality assurance records on file to support the upgrading of this valve. When appropriate records are received, this valve will be neither a deficiency or a defect. (See APCo P.O. FNP2-55, Rev. 84, dated 10/11/79). Valve E21V304 also could cause a failure in the charging pump assuming check valve QV188 fails to prevent backflow and valve E21V304 is being replaced.

Assuming the valve body could have an undetected defect leading to failure of the valve body, it has been determined that valves E21V304, E21V210 E13V007A, and E13V007B could have a cormon deficiency which constitutes a substantial safety hazard and which could have adversely affected the safety of operations of the nuclear power plant at some time during the lifetime of the plant.

This deficiency represents a deficiency found in design, which were it to have remained uncorrected, could have af fected adversely the safety of operations of the nuclear power plant at some time during the expected lifetime of the plant.

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This deficiency does not constitute a significant breakdown in the quality assurance program conducted in accordance with the requirements of Appendix B. The deficiency appears to be an isolated instance of human error in QA program implementa-tion and is not sufficient in number to indicate a significant breakdown in the QA program.

The deficiency represents a significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit. The deficient valves are correctly showa on drawings as Class 2 valves but are incorrectly shown on bill of material and specifications as Class 3 valves.

The deficiency does not represent a significant deficiency in the construction of or significant damage to a structure, system or component nar is it a significant deviation from performance specifications.

Corrective Action:

Valves will either be replaced or upgraded to Class 2 by obtaining proper documentation from the manufacturer.

Sunr.ary and

Conclusion:

(1) This deficiency, were it to have remained uncorrected, could possibly have adversely affected the safety of operations of the nuclear power plant at some time during the expected lifetime of the plant.

(2) This deficiency does not represent a significant breakdown of the quality assurance program.

(3) The deficiency represents a deficiency in the final design as approved and released for construction.

(4) The deficiency does not represent a significant deficiency in construction of or significant damages to a component.

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4 (5) The deficiency does not represent a significant deviation from performance speci-fications of a component.

This deficiency also represents a substantial safety hazard as defined by 10CFR21 and this report also satisfies the reperting requirements of 10CFR21.

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