ML20099C599
| ML20099C599 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/02/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| REF-PT21-84 ANPP-31044-TDS, DER-84-37, NUDOCS 8411190598 | |
| Download: ML20099C599 (6) | |
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Arizona Public Service Company.
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. November 2, 1984 gy.,* W ANPP-31044-TDS/LBS L
' U.' S. Nuclear Regulatory Commission Region Vf
- 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 Final Report - DER 84-37
'A 50.55(e) Reportable Condition Relating To Unqualified t
Sealant In Essential HVAC Ductwork.
Filet 84-019-026; D.4.33.2
Reference:
' A) Telephone Conversation between P. Narbut and T. Bradish on 3
May 10; 1984 B) ANPP-29724, dated June 12, 1984 (Interia Report)
C) ANPP-30350, dated August 29, 1984 (Time Extension)
D) ANPP-30565, dated September 19, 1984 (Time Extension)
Dear Sir I
Attached is our final written report of the Reportable Deficiency under 10CFR50.55(e), referenced above.
Very truly yours, b
cr u._ D n t w E. E. Van Brunt, Jr.
APS Vice President
):uclear Production J.NPP Project Director I
EEVB/LBS/nj l
Attachment l
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LMr. T. W. Bishop 1
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' DER 84-37:
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- cet Richard DeYoung; Director s
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- Office of Inspection and Enforcement U. S. Nuclear Regttlatory Commission Washington,.D..C. 20555
.T..G. Woods, Jr.
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'D.'B. Karner
- W. E. Ide D. B. Fasnacht 4
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A.'C. Rogers L. A. Souza.
D. E. Fowler T. D. Shriver C. N. Russo B.'S. Kaplan.
J.-.Vorees J. R. Bynum'
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R. W. Welcher H. D. Foster
-D. R. Hawkinson R. P. Zimmerman L. Clyde r
M. Woods T. J. Bloon D. N. Stover J. D. Houchen J. E. Kirby D. Canady:
Records Center Institut.e of Nuclear Power Operations l
1100 Circle 75' Parkway,-Suite 1500 Atlanta, GA 30339 i
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'IINAL REPORT.---DER 84 37...,'
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. DEFICIENCY EVALUATION 50.55(e)=
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. Description of Deficiency 1 M
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Sections of the~HVAC ductwork'are connected together'at. joints by.
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' bolted flanges Lwhich are ' welded to the ducts. - Specification let-598:
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-Exhibit.D, Section D.6.3.14 requiresithat neoprene' gaskets be used'st m,;
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'all.~ connections between duct and equipment (dampers,' air handling?
un ts, etc.) and'between duct joints having' flanges..> The-A 5
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' ' specification also states that sealants mayLbe.used only on duct i
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' joints which~do not;have' gaskets. The Waldinger Corporation l(TWC),-
A J the HVAC subcontractor, has verified that all duct joints at:PVNGS~
is have gaskets. ;The specification-does not address (the use ofl sealants-2for other purposes.'
' The specification. requires that all duct syst'ensibel pressure tested
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,under positive pressure for adherence:to maximum leakage requirements'
-(D.6.3.3).
Before the actual test was performed, TWC Q/Arpersonnel-pressurized the duct systems to verify conformance to the leakage =
requirements,,and found that 'certain sections of the ducting systems 7 would not meet these requirements. - To reduce leakage to the specified a
maximum limits, various sealants were applied by TWC construction
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'I personnel under the direction of a TWC construction foreman. Tk'C Q/A personnel accepted the use of these unqualified sealants without questioning the qualification or correct uses of themsealants. These sealants were used in over 100 different locations in. Units 1, 2, and 3 Fuel, Control, Diesel Generator and Auxiliary Buildings. ' At variance to the specification, sealant was applied to gaps in the i
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gasket-metal seal, in abandoned screw holes, around instrumentation and fire damper electrothermal link penetrations, and around sheet l
metal screws used in securing fire. damper flashing. These' applications of sealant were not included in the specification nor addressed in any TWC documents submitted for acceptance. 'The use of unauthorized sealant w.1s discovered by NRC' inspection on
.Tanuary 29, 1984 and a Noncen*ormance Report'(NCR #798F) was issued.
The NRC inspector inquired dout the environmental qualification of the sealants used, and it was determined that there was no existing i
j qualification report.
W TWC was requested to identify the type and number of sealants used.
l This was done via a walkdown and inspection'of HVAC systems in Units 2 and 3.
This inspection identified 21 types of sealants available i
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for use at the jobsite (Reference letter F-TWC-BCI-84-258, j
September 5,1984) and by comparing color and texture,.. eighteen.
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different types of sealants were found to have actually been used (see t Intter F-TWC-84-314, October 5,1984). This inspection also determined the locations of their use. To date, Unit 1 inspection and walkdown has revealed that no additional sealants were used.
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f According to Final Safety' Analysis Report (FSAR), Section 1.8 and Regulatory Guide 1.52, ~ sealants must-be qualified.for.-their,-
,Jpost-accident environments. LFSAR Section 1.8 states that.the design for essentia12 atmosphere; cleanup system. air filtration and absorption
-units'shall c'omply with' Regulatory.Gude 1.52.
This guide applies to D
Essential Safety Features =(ESF) Ventilation Systems.- (The' Diesel:
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Generator, Control, Fuel and Auxiliary Buildings all have ESF
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Ventilation Systems.) Section C.2(e) states that all materials used.
in ESF Ventilation' Systems should effectively perform.their intended-function under the postulated radiation levels. There is.no
' qualification documentation for these-sealants. The sealants must be qualified in accordance with the post-accident environmental
- conditions as stated in Specification MM-598 (Reference letter B/ANPP-M-114879, May 14, 1984). There are no post-accident
_ qualification requirements for non-ESF equipment since this equipment:
performs no post-accident functions.
Evaluation TWC has constructed test assemblies to duplicate the duct configuration for the various applications of sealant- (i.e., if an abandoned hole was found filled with sealant, a hole'was' drilled in the test assembly and filled with the type of sealant' used). The. test assemblies consist of 2 - 12" x 12" ducts gasketed together and with sealant applied. These assemblies, along with samples of sealant, were sent to a qualification test lab for testing (see letter-F-TWC-BCI-84-258, September 5, '1984). Chemica1' analysis of the scalants have been completed. Environmental analysis was completed on the assemblies as' outlined in the Environmental Qualification Program (M598-2125). The qualification ' report (Reference Report No. 84-1871, September 27, 1984) received by TWC on October 4,1984 is proprietary and will be retained by TWC. TWC has informed. Bechtel that all test assemblies, samples, and sealants passed the Environmental H
Qualification Program. This program' consisted of an aging test, a radiation exposure analysis, a positive pressure / leakage test, and a deflection (elasticity) test. The program' qualifies the sealants for a 5-year' life (Reference F-TWC-BCI-84-308, October 4,1984).
-Additionally,-Bechtel is directing TWC to proceed with the test program to environmentally qualify the sealants for a 25-year life.
The root cause of this defial acy is the failure of the TWC craftsmen to follow the TWC HVAC installation procedures,"and the failure of TWC inspection personnel to detect this deviation from procedure.
4 Since TWC had an approved QA/QC program, their inspection personnel had the' responsibility for inspection of the systems installed by TWC.
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[II.
Analysis of Safety Implications
. The-sealants are qualified for's period of 5" years,.while the gaske'ts
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' are qualified:for 9 to 25 years depending upon their location; (Reference M598-1990, Table.I, page 7b). >Therefore, sealant-qualification.would expire prior to gasket. replacement. Additionally,' ;
there are some locations where sealant.was used (abandoned screw
- holes, etc.) in which, had this deficiency gone uncorrected, the sealant may-never have.been replaced. Therefore, in this situation, operation of the Control, Auxiliary, Diesel Generator, and-Fuel-
. Buildings HVAC systems may be suspect and would constitute a possible
- safety hazard.
Therefore, this condition is evaluated as reportable under the-requirements of 10CFR50.55(e),.since it also represents a significante breakdown in the' quality assurance program.
This condition is evaluated as reportable under 10CFR Part 21, since
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the defect exists 1n a basic component.
III. Corrective' Action All unauthorized and/or unqualified sealants used in the ESF Ventilation Systems installed by the Waldinger Corporation in the Control, Diesel Generator, Fuel, and Auxiliary Buildings have been identified. The various sealants have been applied to duct test samples and tested under an environmental qualification program consisting of aging, elasticity, and leakage tests, and a radiation exposure analysis. The Walainger Corporation has received the test report (Report NO. 84-1871, September 27, 1984) certifying'that the-sealants have passed the Environmental Qualification Program.- The Waldinger Corporation has supplied documentation stating that the sealants used in the ESF Ventilation Systems installed in the control, Fuel, Diesel Generator, and Auxiliary Buildings are qualified for-the environmental conditions that the sealants may be exposed 'to for a life of 5 years (see letter F-TWC-BCI-84-308, October 4,1984).. A matrix giving the locations of the sealant applications for each unit will be supplied by TWC for incorporation into the plant maintenance program. Also, TWC will submit a Supplier Deviation Disposition Request (SDDR) to document their use of sealants in the ESF HVAC systems. The location matrix and SDDR vill be reviewed to ensure that all instances of sealant use have been identified and addressed.
The Waldinger Corporation initiated a retraining program for craf t, engineers, and QC inspectors on April 19, 1984. This includes the proper uses of sealants in ESF Ventilation Systems (Reference F-TWC-BPC-84-114).
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idl Final Report DER 84-37 Page Four; r
Allsealantshavebeenremovedtoacentrallochtionunderthedirect control of the Waldinger Project Engineer and are being surveyed by Waldinger quality control (Reference B/ANPP-M-116507, June 22,1984).
Additionally, the following corrective actions have been instituted to intensify control of HVAC installations-1.
Bechtel Construction QC surveillance of "Q" subcontract documentation and work activities are conductedd on a daily basis. When a subcontractor is actively invcived in "Q" work, a QCE will be assigned'to survey the activities.
2.
The Field Subcontracts organization has been instructed'to direct the subcontractors to submit and document, via the Supplier Deviation Disposition Request (SDDR) process, all requests for deviations from specifications.
3.
A process has been instituted to review subcontractor documentation for completeness and compliance to the subcontract for all work performed.
4.
More emphasis has been placed by QA on surveillance of hardware installations.
- 5. All new construction subcontract personnel are required to attend a Quality Orientation Program.
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