ML20116A912
| ML20116A912 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/05/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| REF-PT21-85, REF-PT21-85-238-000 ANPP-32326-TDS, DER-85-04, DER-85-4, PT21-85-238, PT21-85-238-000, NUDOCS 8504240639 | |
| Download: ML20116A912 (5) | |
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Arizona Nuclear Power Project
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P.O. BOX 52034
- PHOENIX. ARIZONA 85072-2034 April 5, 1985 ANPP-32326 -TDS/PJC U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane - Suite 210 Walnut Creek, CA 94596-5368 Attention: Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects
Subject:
Final Report - DER 85-04 A 50.55(e) Reportable Condition Relating to Type 'A' Fire Damper Installation File: 85-019-026; D.4.33.2
Reference:
A) Telephone Conversation between L. Miller and T. Bradish on February 11,1985.
B) ANPP-32094, dated March 8,1985 (Interim Report)
Dear Sir:
Attached is our final written report of the Reportable Deficiency under 10CFR50.55(e), referenced above.
Very truly yours, O.Lk
%LL,
E. E. Van Brunt, Jr.
Executive Vice President Project Director i
EEVB/PJC/rlm Attachment cc:
See Page Two l
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ANPP-32326-TDS/PJC Mr. D. F. Kirsch DER 85-04 Page Two cc Richard DeYoung, Director Office Otf Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 D. B. Karner W. E. Ide D. B. Fasnacht A. C. Rogers L. A. Souza D. E. Fowler T. D. Shriver C. N.s.Russo B. S."Kaplan J. R. Bynum J. M. Allen D. Canady A. C. Cehr W. J. Stubblefield W. C. Bingham R. L. Patterson R. W. Welcher H. D. Foster D. R. Hawkinson R. P. Zimmerman M. L. Clyde M. Matt T. J. Bloom D. N. Stover
~J. D. Houchen J. E. Kirby Records Center Institute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta, CA 30339 L_.
FINAL REPORT - DER 85-04 DEFICIENCY EVALUATION 50.55(e)
ARIZONA NUCLEAR POWER PROJECT-(ANPP)
PVNGS UNITS 1,2,3
-I.
DESCRIPTION OF DEFICIENCY During a walkdown of the Unit 3 Type "A" fire dampers, it was discovered that the dampers were not installed in accordance'with the manufacturer's installation instructions. The dampers are required to be fastened on-both sides to the sleeves in which they.are installed with~either 1/4-20 bolts, No. 10 screws or 1/2-inch long welds. The fasteners are required to be staggered intermittently and spaced 8 inches maximum center-to-center (C-C) for three-hour rated dampers and 12 inches maximum C-C for two-hour rated dampers. These installation instructions comply with Underwriters Laboratory safety standards. Contrary to this requirement, both the three-hour and two-hour Type "A" dampers at PVNGS were fastened on only one' side with 1/2-inch long welds spaced 12 inches apart.
The tag numbers of the affected dampers are as follows:
Tag Number Rating (hours)
HAN-M28A, 28B, 300, 301 3
HAN-M29B, 30A,-130 2
HDA-M03 3
HDB-M03 3
HJA-M64, 67, 69, 70, 71, 101, 102 3
HJB-M20, 65, 67, 68, 71, 103, 105 3
HJN-M30, 32, 102 2
HJB-M17, 18, 104 2
'HJN-M23, 43 3
HPN-M01, 2 3
HSN-M101 1
(same requirements as two-hour rating)
HTN-M31, 32 2
Specification 13-MM-598 requires that the as-installed condition of these dampers be such that their UL rating is maintained. Compliance of the above Type "A" dampers with the UL requirements is indeterminate due to the installed configuration.
The subject dampers are manufactured by Ruskin Manufacturing Company and supplied and installed by The Waldinger Corporation.
EVALUATION Although the manufacturer had submitted proper damper installation instructions (References 1 and 2), they were not used.
Instead the dampers were installed in accordance with Subcontractor Change Request (SCCR)_FW-121. This document specified that Type "A" dampers be welded
Attachment ANPP-32326-TDS/PJC Mr. D. F. Kirsch DER 85-04 Page 2 in place with 1/2-inch welds spaced 12 inches apart. Additionally, the SCCR was unclear as to whether or not both sides of the damper should be welded; i.e., the drawing indicated welds on both sides, but the veld symbol did not.
Consequently, the dampers were welded on one side only. The root cause of this condition is attributed to Waldinger's failure to follow certified installation instructions issued by Ruskin and Bechtel's approval of the SCCR without adequate technical justification.
The dampers are required to maintain their integrity for the duration of their hourly rating to control the spread of fire. Failure to perform their intended function could result in the uncontrolled spread of fire through safety-related areas. It has not been deter-mined whether or not the "as-built" configuration would degrade the hourly rating of the subject dampers; this would require extensive evaluation and testing. Therefore, it has been assumed that this condition would impair the safety function of the dampers.
This condition is common to the dampers listed in Section I for Units 1, 2 and 3.
The solution of this problem is to fasten the dampers in accordance with the manufacturer's instructions.
II.
ANALYSIS OF SAFETY IMPLICATIONS Based on the above, this condition is evaluated as Reportable under the requirements of 10CFR50.55(e) since, if this condition were to remain uncorrected, it could represent a significant safety condi-tion.
The Project also has evaluated this condition as Reportable under 10CFR Part 21.
This report addressed all the reporting requirements of the regulation with the exception of Subpart 10CFR21.21(b) (3) (VI) regarding the number and location of such components supplied to other facilities.
III. CORRECTIVE ACTION The dampers will be fastened in accordance with the manufacturer's instructions; this will assure the UL certification is maintained ~.
The dampers listed in Section I will be fastened on the side not secured to the sleeve, and the three-hour dampers will receive additional fasteners to comply with the 8-inch C-C spacing. The dampers will be fastened by either welds, bolts or screws, or a combination of the same. The work will be performed under the following documents:
Unit 1 - EER 85-HA-012 Unit 2 - NCR SM-5558 Unit 3 - NCR MJ-2569 The physical work for Unit 1 is complete. Unit 2 and 3 rework will be completed prior to Operating License for each Unit.
i 4..
' Attachment
>. Mr. D.-F. Kirsch DER'85-04 Page 3
- IV.
REFERENCES 1.
Ruskin Fire'~ Damper Installation Instructions'-
- Bechtel Log No. M598-89 2.
Ruskin' Fire. Damper Installation Instructions Bechtel Log No. M598-2024
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