ML19346A144

Revised Deficiency Rept Re Diesel Generator Fuel Oil Tank Room Fan Motor Qualification,Essential Cooling Water Gantry Crane Tornado Design & Emergency Sump Recirculation Piping Stress.Repts Should Be Per 10CFR21,not 10CFR50.55(e)

ML19346A144
Person / Time
Site:	South Texas
Issue date:	05/18/1981
From:	Rice W BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
REF-PT21-81-438-000 PT21-81-438, PT21-81-438-000, NUDOCS 8106050265
Download: ML19346A144 (6)

Text

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, yf/ 00 0 BrownffRootJnC. Post office Box Three, Houston, Nvas 77001 .

A Hallitsurton Company Wilt; m M. Rice 47N O Group Vice President Power Group (713) 676-3521 May 18,1981 A gfcc349/ ' 'R S Q.

I Mr. Victor Stello, Director Office of Inspection and Enforcement D' I

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U. S. Nuclear Regulatory Comission 5% M / ()

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,10 Washington, D. C. 20555 q, .

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Dear Mr. Stello:

_. v6 Pursuant to the discussion on May 15, 1981 among your Mr.'Potapovs (Region IV) and our Messrs. K. R. Cook and P. S. Jordan, this letter provides written notification of three (3) reportable defects (see attachments) under 10CFR21 regarding Brown & Root design activities.

l Our three determinations have been made as the result of re-review of previous concerns in accordance with Brown & Root comitments made to .

I your Mr. Dan Fox during Brown & Root Inspection 81-02 of April 1981.

As the result of certain procedural and documentation concerns noted by Mr. Fox regarding Brown & Root's past implementation of 10C7R21, Brown &

l Root comitted the following:

1. Review all items previously submitted to the Brown & Root l Incident Review Committee (IRC) for specific consieration under the provisions of 10CFR21.

2. For any item considered to be reportable under Part 21, Brown & Root shall assure that 10CFR21 reporting require-ments have been met. To complete any outstanding re-porting requi*ements, Brown & Root may submit documentation to the Nuclear Regulatory Comission (NRC) which supplements information already provided in written reports submitted pureuant to 10CFR50.55(e).

3. Brown & Root is to review its procedure governing implemen-tation of iOCFR21 and revise the procedure as necessary to assure it properly reflects actions, documentation, and reporting requirements of 10CFR21.

The above actions are to be complete by July 1,1981.

The re-review by Brown & Root of past IRC items is currently in progress.

Three (3) of these previous items are detennined at this time to have been more properly reported pursuant to 10CFR21 based on our current understanding of the regulations. Each of the three items was reported under 10CFR50.55(e) and final reports have been submitted to the NRC.

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Mr. Victor Stello, Director May 18,1981 Page 2 These items are as follows:

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1. Diesel Generator Fuel Oil Storage Tank Room Fan Motor Qualification 2 .. Essential Cooling Water Gantry Crane Tornado Design

3. Emergency Sump Recirculation Piping Overstress These reportable defects are discussed in attachments 1 through 3, respectively. They pertain to the South Texas Project, Units 1 and 2, for which Brown & Root is the En3.neer and Constructor. Each of the three defects basically involves the failure by Brown.& Root to trans-late design requirements into final design.

As previously stated, our re-review of past items is continuing. We c

shall provide requisite notification to the NRC of any additional .

deficiencies determined to be reportable pursuant to 10CFR21. Additional

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questions regarding this matter should be addressed to Mr. K. R. Cook, (713)676-8860.

Very truly yours, BROWN & R00T, INC.

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! J-W. M. R ce Group Vice President l WMR/PSJ/vm cc: Karl V. Seyfrit, Director Office of Inspection and Enforcement - Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76102 D. G. Barker, Manager - South Texas Project Houston' Lighting & Power Company P. O. Box 1700 Houston, Texas 77001

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Attachment 1 Diesel Generator Fuel Oil Tank Room Fan Motor Qualification

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The South Texas Project (STP) Units 1 & 2 are each provided with a Diesel Generator Building (DGB). Each DGB houses three (3) fuel oil storage tanks in adjacent but separate rooms. Each of the three (3) rooms .is ventilated by its respective motor-driven exhaust fan. In accordance with plant-specific regulatory requirements, the fan motors are to be provided with a reliable source of power, i.e. powered from an engineered safety features (ESF) bus.

As the result of a routine design review related to electrical loads, the fan motors were identified as non-Class IE designed motors to be powered from ESF buses, Class IE power sources. In order to meet electrical separation requirements of Regulatory Guides 1.32 and 1.75, the motors must be Class TE qualified. The Class IE interface require-ment was not properly translated by Brown & Root (B&R) into the final design and procurement document of the fan / motor assemblies. The fans l have been delivered to STP.

This item was initially reviewed on June 19, 1980 and determined .

l reportable pursuant to 10CFR50.55(e) on that date. Houston Lighting &

Power Company (HL&P) provided verbal notification to the Nuclear l

Regulatory Commission (NRC) on June 20, 1980. Reportability pursuant i to 10CFR21 relative to the equipment supplier was detennined not applicable since the nonconforming condition was caused by B&R.

Detailed information regarding this deficiency was provided in HL&P written reports to the NRC as follows:

16 JUL 80 30-Day Report (ST-HL-AE-497) i 3 SEP 80 Final Report (ST-HL-AE-523)

This item was re-reviewed on May 13,1981 by B&R and detennined to be reportable pursuant to 10CFR21 based on our current understanding of the provisions of 10CFR21. The basis for this deficiency is that the fan motors were to be supplied from a Class IE power source but were not properly qualified to meet electrical separation require-ments. B&R failed to properly specify design requirements in the procurement document.

To correct the deficient condition, the fan motors will be replaced with

! motors qualified to Class IE requirements. Because of the unique design situation related to this deficiency, no general recurrence control program was considered necessary.

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Attachment 2 Essential Cooling Water

' (ECW) Gantry Crane Tornado Design l The South Texas Project (STP) Units 1 and 2 are provided with an essential cooling pond (ECP) which serves as the ultimate heat sink. The ECP is shared by both units. Water is provided from the ECP for various safety-related cooling purposes by essential cooling water (ECW) pumps located in the ECW intake structure which is designed to seismic Category I requirements. A gantry crane is provided at the structure to service the equipment housed in the structure. The ECW gantry crane is required l

to be designed such that it cannot unacceptably interact with the Category I ECW intake structure as the result of severe natural phenomena, e.g. seismic or tornado events.

Contrary to design requirements, the crane was released for fabrication without adequately accountirig for design basis tornado wind loads.

This was the result of Brown & Root (B&R) failing to properly include tornado wind loadings in the procurement document. The crane was fabricated by the manufacturer in accordance with the specifications -

of the procurement document. The crane has been shipped to STP.

This item was initially reviewed on May 15, 1979 and determined report-able pursuant 10CFR50.55(e) on that date. Houston Lighting & Power Company (HL&P) provided verbal notification to the Nuclear Regulatory Comission (NRC) on May 16, 1979. Reportability pursuant to 10CFR21 was evaluated relative to the crane supplier. Because the nonconforming

! condition was caused by B&R, it was determined that a reportable deficiency pursuant to Part 21 was not applicable to the supplier.

Detailed information regarding this deficiency was provided !n HL&P written reporte to the NRC as follows:

15 JUN 79 30-Day Report (ST-HL-AE-351 )

9 OCT 79 Final Report (ST-HL-AE-381 )

This item was re-reviewed on May 13, 1981 by B&R and determined reportable pursuant to 10CFR21 based on our current understanding of the provisions of 10CFR21. BAR's failure to adequately specify the tornado wind loadings to be used by the manufacturer in crane design could result in the crane's structural failure in a tornado l

event and impact the ECW structure, an unacceptable interaction.

As stated in HL&P's reports, corrective action consists of extending the crane rail structure a sufficient distanca from the ECW structure l

so that failure of the crane in the stowed position will not result i

in ECW structure impact. Additionally, programmatic changes have been i

effected relative to B&R design verification to assure non-safety related seismic Category I structures and components are included in the design verification program. This procedural modification was made retroactive.

Attachment 3 Emergency Sump Recirculation Piping Overstress The units 1 and 2 reactor containment buildings (RCB's) for the Scuth Texas Project (STP) are each provided with three (3) emergency sumps.

The purpose of these sumps is to provide a collection point for water following a loss of coolant accident (LOCA) and provide the point of suction for the safety injection system (SIS) and containment spray system (CSS) pumps in the post-LOCA recirculation mode of operation.

The suction pipe from each sump is comon to the respective train of SIS / CSS pumps for a total of three (3) trains. The emergency sump liner-to-pipe joint is a welded connection.

During a design review performed by Brown & Root (B&R), it was dis-covered that the welded connection between the pipe and sump liner as designed did not adeqw.cely include all appropriate loads. Consec.uently, B&R determined that this weld would fail under design loading conditions and that operability of the associated recirculation valve could not be guaranteed. Because this problem could affect all three (3) SIS / CSS trains per unit, it was considered a comon mode failure which could '

result in a loss of safety system function. The design had been released for construction.

This design deficiency was initially reviewed on October 24, 1979 and determined reportable pursuant to 10CFR50.55(e) on that date. Houston Lighting & Power Company (HL&P) provided verbal notification to the Nuclear Regulatory Comission (NRC) on October 25, 1979. Detailed information regarding this deficiency was provided in HL&P written reports to the NRC as follows:

21 NOV 79 30-Day Report 19 MAR 80 Interim Report g(ST-HL-AE-394) r-HL-AE-431) 30 MAY 80 Final Report (ST-HL-AE-47C) 22 AUG 80 Supplemer.t (ST-HL-AE-515)

This item was re-reviewed on May 13, 1981 by B&R and determined reportable pursuant to 10CFR21 based on our current understanding l of the provisions of 10CFR21. B&R's failure to adequately incorporate l

design loads into the sump liner-to-pipe joint could have resulted

[ in loss of safety system function during post-LOCA recirculation.

As stated in HL&P's reports, the corrective-action consists of modifying the design to include added pipe anchors and adding an expansica joint to the process pipe inside the emergency sump. Additionally, pro-gramatic modifications were effected to correct a weakness in the design verification activity to prevent recurrence of this deficiency.

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