ML20101Q449
| ML20101Q449 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/17/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-31498-TDS, DER-84-37, PT21-85-159, PT21-85-159-000, NUDOCS 8501070624 | |
| Download: ML20101Q449 (6) | |
Text
im EIVS Arizona Nuclear Power Project 9 E 2 0 l't ;0- ! '~
P.O. BOX $2034
- FHOENIX. Aal2ONA 85W2-2034 December 17, 1984 ANPP-31498-TDS/IRlr,,,; ; '/ L r U. S. Nucicar Regulatory Commission Region V 1450 Maria Ione - Suite 210 Walnut Creek, California 94596-5368 Attention: Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects
Subject:
Final Report Revision 1 - DER 84-37 A 50.55(e) Reportable Condition Relating To Unqualified Sealant In Essential HVAC Ductwork.
File: 84-019-026; D.4.33.2 Referencet A) Telephone Conversation between P. Narbut and T. Bradish on May 10, 1984 B) ANPP-29724, dated June 12,1984 (Interim Report)
C) ANPP-30350, dated August 29, 1984 (Time Extension)
D) ANPP-30565, dated September 19, 1984 (Time Extension)
E) ANPP-31044, dated November 2,1984, (Final Report)
Dear Sir:
Attached is Revision 1 to our final written report of the Reportable Deficiency under 10CFR50.55(e), referenced above. This Revision updates the Condition Description and Corrective Action as requested at the NRC Exit Meeting November 30, 1984.
Very truly yours, l
q.
c.E Au E. E. Van Brunt, Jr.
APS Vice President Nuclear Production ANPP Project Director EEVB/TRB/p1k Attachment cc See Page Two 8501070624 841217 gDRADOCK 05000528 PDR ll ff27 e
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Mr. D. F. Kirsch DER 84-37 Page Two cc:
Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commis sion Washington, D. C.
20535 T. G. Woods,'Jr.
D. B. Karner W. E. Ide D. B. Fasnacht A. C. Rogers L. A. Souza D. E. Fowler T. D. Shriver C. N. Russo B. S. Kaplan J. Vorees J. R. Bynum J. M. Allen A. C. Gehr W. J. Stubblefield W. G. Bingham R. L. Patterson j
R. W. Welcher
- 11. D. Foster D. R. llawkinson l
R. P. Zimme rman L. Clyde M. Matt i
T. J. Bloom D. N. Stover J. D. Ilouchen J. E. Kirby l
D. Canady Records Center Institute of Nucicar Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, CA 30339 l
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FINAL REPORT - DER 84-37 DEFICIENCY EVALUATION 50.55(e)
ARIZONA PUBLIC SERVICE COMPANY (APS)
PVNGS UNITS 1, 2, 3 I.
Description of Deficiency Sections of the HVAC ductwork are connected together at joints by bolted flanges which are welded to the ducts. Specification MM-598 Exhibit D, Section D.6.3.14 requires that neoprene gaskets be used at all connections between duct and equipment (dampers, air handling units, etc.) and between duct joints having flanges. The specification also states that sealants may be used only on duct joints which do not have gaskets. The Waldinger Corporation (TWC),
the HVAC subcontractor, has verified that all duct joints at PVNGS have gaskets.
The specification requires that all duct systems be pressure tested under positive pressure for adherence to maximum leakage requirements (D.6.3.3).
Before the actual test was performed, TWC craft personnel pressurized the duct systems to verify conformance to the leakage requirements, and found that certain sections of the ducting systems would not meet these requirements. To reduce leakage to the specified maximum limits, various sealants were applied by TWC construction ~
personnel under the direction of a TWC construction foreman.
TWC craft supervisory personnel accepted the use of these unqualified sealants without questioning the qualification or correct uses of the scalants. These sealants were used in over 100 different locations in Units 1, 2, and 3 Fuel, Control, Diesel Cenerator, Auxiliary Buildings and Containment. At variance to the specification, sealant was applied to gaps in the gasket-metal seal, in abandoned screw holes, around instrumentation and fire damper electrothermal link penetrations, and around sheet metal screws used in securing fire damper flashing. The use of unauthorized sealant was discovered by NRC inspection on January 29, 1984, and a Nonconformance Report (NCR
- 798F) was issued. The NRC inspector inquired about the environmental qualification of the sealants used, and it was determined that there was no existing qualification report.
TWC was requested to identify the type and number of sealants used.
This was done via a walkdown and inspection of HVAC systems in Units 2 and 3.
This inspection identified 21 types of sealants available for use by TWC personnel at the jobsite. This inspection also determined the locations of their use. Unit 1 inspection and walkdown has revealed that no additional sealants were used.
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Final Report DER 84-37 Page Two According to Final Safety Analysis Report (FSAR), Section 1.8 and Regulatory Guide 1.52, sealants must be qualified for their post-accident environments.
FSAR Section 1.8 states that the design for essential atmosphere cleanup system air filtration and absorption units shall comply with Regulatory Gude 1.52.
This guide applies to Essential Safety Features (ESF) Ventilation Systems.
(The Diesel Generator, Control, Fuel and Auxiliary Buildings and Containment all have ESF 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 senlant applied. These assemblies, along with samples of sealant, were sent to a qualification test lab for testing. Environmental analysis was completed on the assemblien as outlined in the Environmental Qualification Program (M598-2125). The qualification test report (Reference Drawing Log No. M598-3027) documents that all test assemblies, samples, and sealants passed the Environmental Qualification Program. This program consisted of an aging test, a radiation exposure analysis, a positive pressure / leakage test, and a deflection (elasticity) test. The test qualifies the scalants for a 5 year life.
Additionally, Bechtel is directing TWC to proceed with the test program to environmentally qualify the sealants for a 40 year life.
The root cause of this deficiency is the failure of the TWC personnel to report the use of unqualified and/or unauthorized sealants in the ESF HVAC systems.
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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. Final' Report DER 84-37 Page Three
- II.
Analysis of Safety Implications The scalants are qualified for a period of 5 years, while the gaskets 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, Fuel Buildings and Containment HVAC systems may be suspect and would constitute a l
possible safety hazard.
Therefore, this condition is evaluated as reportable under the requirements of 10CFR50.55(e), since it also represents a significant breakdown in the quality assurance program.
This condition is evaluated as reportable under 10CFR Part 21, since the defect exists in a basic component.
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III. Corrective Action All unqualified sealants used in the ESF Ventilation Systems installed' l-by the Waldinger Corporation in the Control, Diesel Generator, Fuel, Auxiliary Buildings and Containment have been identified. The various l
scalants 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 test report certifies 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, Auxiliary Buildings and Containment are qualified for the environmental l
conditions that the sealants may be exposed to for a life of 5 years.
A list giving the locations of the sealant applications for each unit has been supplied by TWC for incorporation into the plant maintenance program. Also, TWC has submitted a Supplier Deviation Disposition Request (SDDR) No.' 3943 to request acceptance of their use of sealants a
In the event that: additional unqualified sealants are discovered in the future, they will undergo an envionmental test to qualify them for
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a 40 year life.
If any sealant does not pass the 40 year qualifiction test, plant maintenance procedures will be implemented to replace this sealant at the end of its qualified life.
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Final Report
' DER 84-37 Page Four The Waldinger Corporation initiated a retraining program for craf t, engineers, and QC inspectors on April 19, 1984. This includes the proper uses of sealaats in ESF Ventilation Systems (Reference F-TWC-BPC-84-114).
All sealants have been removed to a central location under the direct 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 installation:
1.
Bechtel Construction QC surveil (ance of "Q" subcontract documentation and work activities are conductedd on h daily i
basis. When a subcontractor is : actively involved in "Q" work, a i
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QCE will be assigned to survey the activities.
2.
The Field Subcontracts organizhtion 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.
1 4.
More emphasis has been placed by'QA on surveillance of hardware installations.
- 5. All new construction suhqontract personnel are required to attend a Quality Orientation Program.
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