ML20098A146
| ML20098A146 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/12/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-30484-EVB, NUDOCS 8409240322 | |
| Download: ML20098A146 (17) | |
Text
.
r Arizona PubliC Service Company P.O. BOX 21666
- PHOENIX ARIZONA 85036 September 12, 1984 ANPP-30484 -EVB/WEI U.
S. Nuclear Regulatory Commission Region V -
Creekside Oaks Office. Park 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention:
Mr. T.
W.
Bishop, Director Division of Reactor Safety and Projects
Subject:
Response to Notices of Violations and Devia-tions dated August 8, 1984.
Reference:
Letter from T.
W.
Bishop, Director, Division of Reactor Safety and Projects,. Region V,.to Arizona Public Service Company, Attn. E. E.
Van Brunt,-Jr., dated August 8, 1984.
Gentlemen:
The referenced letter transmitted, as Appendix A, a
Notice' of Violation,. dated August 8, 1984, and, as Appendix B,
a Notice of Deviation, dated August 8, 1984.
Such Notices
-were the result of the inspection conducted during the period
~ July 9-13, 1984.
-At'tachments A and B are submitted in response to.
such Notice of Violation and Attachments C and D are submit-ted in response to.such Notice of Deviation.
The referenced letter requests that information respecting certain unresolved items be furnished.
This information will be supplied under separate cover.
If you have questions respecting this response or desire any clarification or verification of any matter dis-cussed in the Attachments, we shall be pleased to respond
- further as you may request.
d&fgl'blSyy Respectfully submitted, 02.g
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Edwin E. Van Brunt, Jr.
Vice President, Nuclear Production N/I 840924 2$
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n-U.:S.; Nuclear Regulatory' Commission September 12, 1984 Page 2 L
cc:
. Richard DeYoung, Director Office ofiInspection and Enforcement U.
Si Nuclear Regulatory Commission Washington,~DC. 20555 T.
G.. Woods, Jr.
'D.
B.
Karner W. E.-Ide' i
D.
B. Fasnacht A..C.. Rogers L.
A.~
Souza D. E.~ Fowler.
T. ' D. Shriver F
J.
N. Russo J. Vorees
'J. R.'Bynum J.
M.' Allen A. C. Gehr W. J.
Stubblefield'
' W. G.
Bingham H. D.
Foster D.
R. Hawkinson R.
P.
Zimmerman
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R.-Frost W.
H.. Wilson J. W. Gross D. Canady E. A.
Licitra J. Houchen J.
Kirby R. Nelson I.- Zeringue Carl Gross Lm-
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STATE OFJARIZONA
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.; County of.Maricopa:-
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[
. I',f Donald B.~.Karner, represent that I am Assistant
-Vice' President,-Nuclear Production of Arizona Public Service Company,-that the foregoing document has been signed by me for
'Edwin'E.-Van' Brunt,.Jr., Vice= President,; Nuclear-Production, on
- behalf ~of: Arizona Public' Service Company with full authority
.to'do so, that I have read such document and-know its contents, and,that to the best of my knowledge and belief, the statements made~~therein are true.
I "d
h Sworn.to before me this 12th day of Septemner, 1984
. W fARA f YNAAh 7 Notary Public m
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'My Commission Expires:
My Commiska Expires Apr!!6,10S7
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ATTACHMENT A 1
i RESPONSE TO NOTICE OF VIOLATION DATED AUGUST 8,'
1984 Section A.I.-
Violation.
As a
result of the inspect *on conducted on July 9-13,
- 1984, the following Notice of Violation dated August 8, 1984 (Notice) was issued:
"A.
10 CFR 50 Appendix'B Criterion V, as addressed in Sec-tion 17 of the ESAR, states in part, activities affect-ing quality shall be prescribed by documented
- instructions, procedures, or drawings
. and shall-be accomplished in accordance with' these instructions, pro-cedures, or drawings.'
"Honeywell procedures PEP 2.1 Rev. 3 (paragraph 5.3),
PEP 2.20 Rev.14 and Drawing No. HON-JHA-902 Rev. L thru N require that the HVAC instrument HJA-TIC-123 enclosure
-be mounted on unistruts, with the unistrut nuts seated correctly on the unistruts, and with full thread engage-ment. Additionally, the correct number and type of wash-ers ' are required inside the enclosure to secure the terminal strips-(blocks) and fuse / switch base plate in
.the enclosure.
" Contrary to the above, during an inspection on July 11, 19.84, of safety-related HVAC instrument 3-J-HJA-TIC-123
~
' in the control room of Unit 3, the following was identi-fied: -(1) enclosure mounting unistrut nut (PC 18 on Drawing No. ' HON-HJA-902 - Rev. N) was found incorrectly
- installed (cocked) on the unistrut such that it did not
'have full thread. engagement with mounting bolt or full loadtbearing surface' contact with the unistrut, (2) the
-lock ' washers (associated with a screw, PC.'No. 34 on Drawing Nos. HON-ZZ-932-1 thru-9 Rev. D) were not in-stalled in all applicable locations, instead flat wash-ers were installed in some locations.'- The screw, nut and lockwasher assembly noted.above are used to secure
-terminal strips (blocks) and. fuse / switch base plates in the -enclosure.
This instrument was installed May 5, 1984 and QC accepted May 14, 1984 on an installation data sheet (form No.-HM-002).
"This is'a Severity Level IV Violation (Supplement II),
Applicable to Unit 3."
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'Section A.2.
-Cause of~the Violation.
~
A.2.1; The cause of the particular discrepant con-
.ditions in the: mounting and assembly of the instrument iden-
~
'tified Jin the -- Notice is attributed ' to incorrect initial l installation by Honeywell. --
Discrep' ant Honeywelli installatiSns were initially.
~
identified on DER 82-81.
DER 84-27 was initiated on a
April 25, 1984 to.do'cument, evaluate and correct deficiencies identified in Unit'2.and 3 where Hone'ywell-installed instru-
- ments'were found to be incorrectly installed.
At the time ithe deficiencies were discovered, it was thought to have been
. caused -by modification 'or removal of instruments after ini-tial Honeywell QC acceptance.
DER 8'4-27 was written to eval-Juate :and _ correct-installation in all three - units as unecessary. ' It does_not. appear'that the subject instruments 0
. have.been: modified or removed ' after Honeywell Inspection.
Therefore,- it -is concluded that the original installation was in; error.
APS shares.the concern expressed in the-Inspection-Report that "on-going work should be correctly performed. "
~
The -need for improved control of' the work of some subcontrac-tors.has been recognized by APS, Bechtel and NRC.
[See May, 1984l Report of the Systematic Assessment of Licensee Perfor-
- mance-SALP Report;and the APS Response filed July 25, 1984.]
The APS Response to the SALP Report (pp. 16-17) described tactions' taken: to - provide such improved controls.
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. actions were. developed ~ and. implemented subsequent to May, 1984, when the -instrument identified in the Notice was par-tial1Y. inst'alled.
Section A.3.
' Response to the-Notice.
A.3.1.
Corrective Steps Which Have Been Taken and Results Achieved.
The specific problems with the instrument-identi-
-fied in sthe Notice will be dealt with through the disposition of-DER 84-27. -The nature, scope and time for completion of the~ corrective measures for disposition of DER 84-27 are set
- forth-in ' detail 'in Section A.'2 of APS' Response to the Notice
~
of Violation', dated August 7,1984,' and for the sake of brev-
-'ity.are incorporated herein by reference.
With respect to assuring improved control of ongo-
- ing HVAC. - hardware installations, the program described in
' APS' ResponseL to the SALP Report has been developed and im-plemented.
Specifically, such program consists of the following:
A.
Bechtel Construction QC surveillance of "Q"'
subcontract documentation and work. activities are con-
. ducted on a daily basis.. When a subcontractor is ac-tively involved in "Q" work, a QCE will be assigned to.
survey the activities.
B.
The Field' Subcontracts' organization has been
. instructed'to direct the! subcontractors to submit and document, via ' the Supplier Design Deviation Request 7
(SDDR)_ process,- all requests for deviations from specifications.
~C.
A process has been instituted to review sub-
. contractor documentation for completeness and compliance U
to the subcontract-for all work performed.
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A-3
y D.
More emphasis has been placed by QA on sur-
- veillance of hardware installations.
. E.
All new construction subcontract personnel are required to attend a Quality Orientation Program.
A.3.2.
Corrective Steps That Will Be Taken To Avoid Further Items of Non-Compliance.
With respect to DER 84-27, see Section A.2 of APS' Response to the Notice of Violation, dated August 7, 1984.
With. respect to on-going HVAC hardware installa-tion, APS and Bechtel QA shall conduct' periodic surveillances to determine-the effectiveness of the. program described in Section A.3.1 hereof.
Modifications 1of such program, includ-
.ing increased' training, will be made as necessary to achieve proper installation of HVAC hardware and accurate and com-plete QC inspections and documentation.
A.3.3.
Date When Full Compliance Will Be Achieved.
With respect to DER 84-27, see Section A.2 of APS'
. Response to the Notice of Violation, dated August 7, 1984.
With respect to the implementation of the above referenced improved controls of HVAC hardware installation, the program will continue in whole or in part until satis-factory on-going performance is achieved.
p A.3.4.
Propriety of Notice of Violation APS considers the issuance of the Notice to be un-warranted since it is contrary to NRC regulations contained in - 10 CFR-Part 2, Appendix C, as detailed in Section A.4 A-4
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J of APS. Response to the Notice of Violation, dated August 7, 1984.
For brevity the description is not repeated here.
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ATTACHMENT B RESP'NSE TO NOTICE OF VIOLATION, DATED AUGUST 8, 1984'
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' Section B.1.
Violation.
.As a
result'~ o'f. the inspection conducted on July 9-13, = 1984, the ' following' Notice of Violation, ' dated
~
August;8,:1984f(Notice) was issued:
- "B.-
10 CFR 50. Appendix A Criterion 2 states _.in part, 'Struc-tures,; systems, and components important to safety shall be~ designed to withstand the effect of natural phenomena such as earthquakes,. tornadoes, hurricanes,
- floods, tsunami, and seiches without loss of capacity to perform their : safety function.
"_ Specification 13-MM-650, revision
- 4. dated March 10, 1982, ' Fire Protection Sprinkler and Spray System, ' sec-tion'D.5.7.2 states in part, 'The piping, supports, an--
chors and restraints for all sprinkler systems located in safety-related.-areas shall be designed to withstand.
Seismic Cat'egory ~IX : requirements.. _. '
Additionally, section' ; DI. 4. 4 states - in part ' Seismic Category IX must be de-
-. structure s, systems,-and components
~ igned to retain structural integrity during and after s
an1SSE but do not have to retain operability for protec-tien.of the public.- The basic requirement is prevention of structural collapse and damage to equipment and structures required for protection of the public safety.'
" Additionally, Specification 13-MM-650 section D.5.7.9 states in part,. ' Contractor (Bechtel) shall review all
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calculations and designs of supports for these (safety-related)' areas and make necessary-modifications to meet Category-IX. requirements.'
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" Contrary to ' the above, the calculations submitted by
- Viking. for fire protection' system piping (Bechtel Log Nc. 13-10407) were accepted, on October 20, 1980, but the calculations do not provide an analysis that' demon-strate the' Fire Protection piping system has been de-I*
-signed to ~ retain structural _ integrity during an SSE seismic event.
The calculations do not demonstrate that longitudinal system and component loads have been con-sidered or raviewed.
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l "This is a Severity Level IV Violation applicable to Units 1, 2 and 3."
Section B.2.
Response to the Notice.
B.2.1 Cause of the Violation.
A BPC Engineering review revealed that the Speci-fication 13-MM-650 did not provide SSE seismic spectra for buildings. This information is necessary in order to perform analyses of the overall fire protection piping system.
Specification 13-MM-650, paragraph 5.7.7 (for safety-related applications) requires the subcontractor to use the criteria in specification attachment D-3 to determine the spacing of pipe supports and the number required, and specifies that pipe support spacings shall not be exceeded for each respective building.
The SSE building response spectra were utilized by BPC Engineering to establish the support spacings and loads given in specification attachment D-3.
Additionally, specification 13-MM-650 does specify, for safety-related applications, that pipe supports, anchors, and restraints be designed to Seismic Category IX.
The defini-tion of Seismic Category IX is included in the specification.
Calculation M-650-2OO prepared and submitted by Viking meets the loading and spacing requirements of Specifi-cation 13-MM-650, attachment D-3.
However, this calculation does not address the overall piping system by analysis to ensure structural integrity during an SSE seismic event.
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The violation is considered to be an isolated event, because specification 13-MM-650 is the only specifi-cation involving subcontractor installed piping where support criteria is provided to satisfy Seismic Category IX require-ments.
B.2.2 Corrective Steps Which Have Been Taken and Results Achieved.
SSE seismic spectra for buildings have been fur-nished to Viking.
Additional analyses are being conducted by Viking to address the adequacy of the overall fire protection piping system to retain: structural integrity after an SSE.
Testing data for the hanger components will be included in the analyses.
The Viking analyses will be reviewed by Bechtel engineering for adequacy.
B.2.3 Corrective Steps Which Will Be Taken to
. Avoid Further Items on Noncompliance.
A documented training session (s) will be conducted for project engineering personnel regarding calculation re-view- _ relationship with specification and licensing requirements.
B.2.4 Date When Full Compliance Will Be Achieved.
Completion and review of the additional seismic analyses and supporting calculations will be completed by October 30, 1984.
B-3
Training-will be completed.b'y September 22,-1984,
.and attendance records will be maintained in the design office training record files.
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ATTACHMENT C
' RESPONSE TO' NOTICE OF. DEVIATION DATED AUGUST 8, 1984 Section C.1'.
Deviation.
.As-a. result of the., inspection conducted on
. July: 9-13, 1984,- the _ following : Notice of Deviation, dated
^
JAugust.8, 1984.' (Notice) was issued:
~
~"A.
FSAR Table.3.2-1 states in part," with respect to the
' Fire Protection System, that: ' Supports and hangers'for _
.non-safety related systems are designed to Seismic Cate-
_ gory - I requirements when failure of the equipment of
-piping could adversely affect a safety-related system.'
'" Specification ; 13-MM-650 revicion 4,
dated March 10, 1982,-section'D.5.7.2 states in part: 'the piping, sup-ports, anchors,.and restraints for all sprinkler systems N*
located in safety-related areas shall.be designed to
. withstand' seismic Category IX' requirements.'
"The specification 13-MM-650 requirement to design fire
. protection' piping supports to Seismic Category. IX is
' contrary to the FSAR commitment to design to Seismic Category'I requirements.
Per the. Project Design Crite-ria Manual' Part II Revision 12 dated September 24~,
- 1982,
. Seismic Category IX design requirements differ in that Category I items are designed-to remain. functional with-in the elast_ic deformation-limits whereas Category _IX items are designed-not to fail (but may deform)."
- Section C.2.
Explanation Regarding-the Deviation.
~
~
C. 2.1 - Specification 13-MM-650 requires that the Fire ' Protection pipe supports and hangers be designed to Seismic Category IX requirements.
The PVNGS requirements are
.those - stated in -the Branch Technical Position APCSB 9.5-1 that " postulated _ fires or fire protection system failures are not considered -concurrent with other plant accidente or the
.most severe' natural phenomena."
Therefore, the fire C-1 L
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T f-i protection system need not be - functional after an SSE,' howev-er, it-should not " damage equipment or structures required for protection of public safety."
The Seismic Category IX requirement meets this criteria and, therefore, Engineering i c;-
-considers.this acceptable.
-Section C.3.-
Corrective Action to be Taken.
~ Note "h" of FSAR Table 3.2-1 shall be revised as follows " supports and hangers for non-safety related systems-
-are designed to Seismic Category IX requirements when failure of ' the ~ equipment 'or piping could adversely affect a
. safety-related system."
~
Section C.4.
Date When Full Compliance Will be Achieved.
A SAR Change Notice will be issued to correct the
' inconsistency by September 15, 1984.
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- ATTACHMENT D RESPONSE TO NOTICE OF DEVIATION,' DATED' AUGUST 8,-1984
.Section D.1.- ' Deviation.
- As :' a. result ~ of; the inspection conducted on'
' July 9 -13 R ~ 1984', the following Notice of Deviation, dated ~
August,8,.1984c (Notid:e)1was issued:
"B.
'The Fire. Protection Evaluation Report,J Amendment 3 dated LApril. 30,'1982,JSection-III, part C.10 states, in re ~
gards to Quality Assurance requirements; ' Audits should-bc conducted and documented to verify compliance with the ; fire: protection program including design and pro-curement ' documents; instructions;. procedures and-draw-ings, and inspection:and. test activities.
^
" Contrary to this-. commitment, no-Quality Assurance au-
~
.dits of-design-and procurement documents,. instructions, procedures, and drawings or-inspection and. test activi-
' ties. for..the spray-on : fire proofing -' work (contract.
13-AM-126) were conducted."
-Section D.2..l Explanation Regarding the Deviation.
-D.2.1--NRC Branch Technical Position (APCSB 9.5.1-1) tSection C.3 requires that a QA program be developed for-Fire
~ Protection ~which includes verficiation-of the effectiveness of.the QA Program "through review, surveillance and-audits."
+
- This '- statement recognizes ' the ' use of reviews and surveil-lance, as well as. audits,, to verify QA Program -effectiveness.
~
This commitment has been met' at' Palo Verde Nuclear Generating
- -Station. ' Specifically, with : resp'ect to spray-on fire proof-
- ing.' work, the effectiveness of the coating is determined by khectypeof'coatingandthethickness of the coating.
Both
- the type and thickness;of the coating were specified in the L
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appropriate contract: (13-AM-126) and verified to have been accomplished through review, surveillance and audit.
Con-L tract 13-AM-126 specifies:
a.
.Use of UL tested and-. approved material.
b.
An overcoat spray of 1/8 inch thick sanded gypsen.
c.
Subcontract verification of coating every 10 square feet.
Although not documented, the subcontractor's moni-toring of-thickness has been confirmed by periodic Bechtel Subcontract Coordinator.probings.
Additionally, Bechtel En-gineering conducted the Fire Protection Design Documentation Walkdown Program per I.P.
5.26-04, Attachment 8.
This walkdown required verification of spray-on protective coat-ings..
Results of the walkdown did not disclose any discrepancies.
The APS Construction Quality Assurance Department
' performed an audit (C83-10) of the Fire Protection. System.
The -audit was to determine'if the Fire Protection System com-plied with project requirements and was completed January 13,
-1984.. The ~ audit' examined the coating thickness on structural
~
steel at randomly selected points to verify it complied with the specification 13-AM-126.
It also verified that the coating requirements for-13-AM-126 complied with U.L.
Fire-Resistance Directory.
No deficiencies were identified.
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~Therefore,- it can'be concluded that a Quality An-au'dit has'been conducted to-verify effectiveness of surance the' Fire. Protection Quality Assurance Program.
This audit l combined with reviews and-surveillance verified' the effec-
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.tiveness of the.QA Programi with ! respect to spray-on fire proo'fing.
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