ML20010F096

Final Deficiency Rept Re Unauthorized Mod of Heating, Ventilation & Air Conditioning Fire Dampers,Initially Reported on 801216.Deficiency Not Reportable Because Condition Would Not Affect Safety of Plant Operations

ML20010F096
Person / Time
Site:	Grand Gulf
Issue date:	08/28/1981
From:	Mcgaughy J MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
10CFR-050.55E, 10CFR-50.55E, AECM-81-301, NUDOCS 8109090365
Download: ML20010F096 (4)

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MISSISSIPPI POWER & LIGHT COMPANY

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office of Inspection & Enforcement '

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U. S. Nuclear Regulatory Commission [ [g'Q Region II 101 Marietta Street, N.W.

j ({ ,,J,J Suite 3100 S E F 0 81981

• Ldi Atlanta, Georgia 30303 u.s.H gta,po" p Attention: Mr. J. P. O'Reilly, Director f

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Dear Mr. O'Reilly:

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416/417 File 0260/15525/15526 PRD-80/71, Final Report HVAC Fire Dampers AECM-81/301

References:

1) AECM-81/ll7, 3/25/81

2) AECM-81/28, 1/15/81 On December 16, 1980, Mississippi Power & Light Compsny notified Mr. J.

Rausch, of your of fice, of a Potentially Reportable Deficiency (PRD) at the Grand Gulf Nuclear Station (GGNS) conetruction site. The deficiency concerns the unauthorized modification of HVAC Fire Dampers.

During the investigation of this deficiency it was discovered that one damper, CV-13G, was a non-safety related damper installed in a safety-relsted po s i t ion. Our Constructor originally intended to track this, along with the unauthorized modif1 cations, under QAR-265 and PRD-80/71.

However, the decision was made to track tl is instead under MCAR-lli, PRE-80/67. This problem will be addressed in that final report.

We have determined that this deficiency would not af fect the safety of operations of the nuclear power plant and is not reportable under the pro-visions of either 10CFR50.55(e) or 10CFR21. Attached is our 'inal report giving our rationale.

Yours truly, 8109090365 8'0028 PDR ADOCK 05000416 G PDR J. P. McCaughy, Jr.

KDS dr ATTACHMENT Jr

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cc: See page 2 Member Middle South Utilities System

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Mr.- J. P. O'Reilly .AECM-81/301 NRC Page 2 cc Mr. N. L. Stampley

-Mr R. B. McGehee Mr. T. B. Conner Mr. Victor Stello, Director Of fice of Inspection & Enforcement U. S. Nuclear Regalatory Commission Washington, D.C. 20555 Mr.' G. B. Taylor South MLas. Electric Power Association P. O. Box 1589 Itattiesburg, MS 39401

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bbe: Mr. D. C. Lutken Mr. J. Letherman Dr. D. C. Gibbs Manager of BWR-6 Licensing Mr. J. N. Ward General Electric Company Mr. J. P. McGaughy, Jr. 175 Curtner Avenue Mr. J. D. Heaton San Jose, CA. 95125 Mr. R. Trickovic Mr. J. W. Yelverton Mr. L. F. Dale Mr. D .M. Houston Mr. C. K. McCoy U. S. Nuclear Regulatory Commission Mr. T. H. Cloninger Division of Licensing Mr. R. A. Ambrosino Washington, D. C. 20555 Mr. A. J. Iosue Mr. G. B. Rogers Mr. S. H. Hobbs Mr. J. Matore

, Mr. L. E. Ruhland U. S. Nuclear Regulatory Commission Mr. D. L. Hunt Division of Licensing Mr. A. G. Wagner Washington, D. C. 20555 Mr. P. A. Taylor PRD File File t

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. 1 Attachment to AECM-81/301 3 i Page 1 of 1 FINAL REPORT POR PRD-30/71 I. Description of the Deficiency _

Type 2 trap door fire dampers were modified in the field by the subcon-tractor, General Mechanical Contractors (GMC), without either the vendor's, American Warming & Ventilation ( AWV), or our Constructor's, Engineering approval. Hinge joints and latches were relocated 90 degrees f rom design location af fecting the geometry of the installation.

The systems affected by this deficiency are the Control Room HVAC System (Z51) and the Battery Room Ventilation System (Z77). The deficiency is applicable to Unit 1 and common. It does not apply to the NSSS vendor.

The possibility existed that, during a seismic event, the safe operation of the control room HVAC system could be af fected if the fire dampers were to fail as a result of the modification.

II. Agalysis of Safety Implications The modified dampers were in the safety-related Control Room HVAC System (Z51) and the Emergency Switchgear and Rattery Room Ventilation System (Z77). Some were also located in various other non-safety-related systems.

Complete as-built data detailing the field modifications was sent to AWV for review and evaluation. The modified dampers were also tested at AWV's direction to ensure proper closure and latching.

The damper vendor then conducted a review of the unapproved modifications and determined that the modified dampers as installed will function and are still in compliance with NFPA codes, UL classification, and seismic requirements. Because of this evaluation it has been determined that this condition would not affect the safety of operations of the nuclear power plant and is not reportable under the provisions of 10CFR50.55(e) or 10CFR21.

III. Corrective Actions Taken The cause of the deficiency was that ertain of our Constructor's personnel permitted the subcontractor, GMC, to modify the fire dampers without proper Constructor or vendor authorization.

All responsible personnel have been instructed that any modification to vendor equipment necessitates prior vendor or engineering approval.

- Since the deficiency was determined to be not reportable, no further corrective actions are required.

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