ML20129E680
| ML20129E680 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/29/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-32510-TDS, DER-84-13, NUDOCS 8506060561 | |
| Download: ML20129E680 (5) | |
Text
t in.cy;g, Arizona Nuclear Power Project' "? -8 /3 ff: } g P.O. BOX 52034 e PHOENIX, ARIZONA 85072-2034 April 29i31985,,,_
ANPP-32510-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, Revision 1 - DER 84-13 A 50.55(e) Reportable Condition Relating to HVAC Acceptance Criteria File:
85-019-026; D.4.33.2
Reference:
A) Telephone Conversation between P. Johnson and T. Bradish on March 13, 1984.
B) ANPP-29229, dated April 5, 1984, (Interim Report)
C) ANPP-31454, dated December 12, 1984, (Final Report)
Dear Sir:
Attached for your informatin is Revision 1 to our final written report under 10CFR50.55(e) referenced above. The updated information provided by this revision includes correction of numerical errors in the Condition Description Section and a re-evaluation of the safety implications based upon calculations performed to determine the impact of supports that were not inspected.
Very truly yours, 1
CA1A ML E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/PJC/rlm Attachment cc:
See Page Two 8506060561 850429 PDR ADOCK 05000528
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PDR i I
ANPP-32510-TDS/PJC Mr..D. F.'Kircch DER.84-13
~Page Two cca:
Richard DeYoung,' Director
' Office of Inspection and Enforcement U.1S. 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. Russo B. S. Kaplan J. R. Bycum J. M. Allen A. C. Cehr W. J. Stubblefield
. W. C. Bingham R. L. Patterson R.-W. Welcher H. D. Foster D. R. Hawkinson R. P. Zimmerman L. Clyde B. T. Parker T. J. Bloom i
D..N.
Stover J. D. Houchen J. E. Kirby D. Canady Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta CA 30339 i
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FINAL REPORT - DER 84-13 DEFICIENCY EVALUATION 50.55(e)
ARIZONA NUCLEAR POWER PROJECT (ANPP)
VI PVNCS UNITS 1, 2, 3 I.
Description of Deficiency As a result of an investigation by The Waldinger Corporation (TWC),
-it was discovered that there are two generic problems which preclude the installed HVAC ducts from complying with the Bechtel-established TWC acceptance criteria for seismic conditions as follows:
A.
Insufficient detail on Bechtel design drawings. Examples of these deficiencies are -
Maximum size of datum plates not specified on Drawing 13-C-00C-011, Detail 4.
Extension of duct band ears is shown "as required" with no maximum given (Reft-FCR #20, 756-C).
B.
Incorrect interpretation of the Bechtel design drawings and Field Change Requests (FCR's) by TWC.
Examples of these deficiencies are:
Knee brace angle does not conform to slope as specified on Drawing 13-C-00C-011, Note 5.
Misinterpretation of DCN #2 on Drawing.13-C-00C-032 by TWC concerning the installation of longitudinal bracing to work points.
The root cause of this deficiency-was failure to provide sufficient detail on engineering drawings and failure during installation to correctly interpret engineering requirements shown on the drawings.
In order to identify individual' installed supports which do not comply with seismic acceptance criteria, Bechtel Engineering initiated a walkdown program to inspect "Q" and "R" HVAC supports and potential hazard conditions (Class "S" supports over Class "Q" and "R" systems).
The potential hazard condition walkdown is for Units 2 and 3 only since a seismic hazards walkdown for Unit I had previously been conducted and FCR's 34, 189-P and 39, 873-P).
In addition, the walkdown was
' limited to existing supports at the time of the inspection and which were physically accessible and not covered by fire-proofing.
Bechtel Engineering developed acceptance criteria and Design Change Packages ISM-HA-030, HD-009, HF-014. HC-040, and HJ-035 were initiated to perform the walkdown inspection in Unit 1.
A summary of the results of the Unit I walkdown are given below:
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- Fin 31' Report -
' DER 84-13' Page Two No. of supports' inspected that meets engineering drawing / criteria requirements 2060
=
No.fof supports inspected that do not meet requirements but are' acceptable by calcu -
lations/ analysis (use-as-is).
445
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- No. of supports inspected that did not.
1 meet acceptance requirements and were dis-
- positioned as " Rework"- and reworked 73
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=-
2578 (91%)'
Total:No.-of supports inspected 1
256 (9%)
Total No.'of supports not inspected
=
2834 -(100%)
Total No..of supports
=
As a result of the 256 supports not inspected in Unit 1, it was
.necessary to determine the impact of those supports on the evaluation.
Calculations =were consequent 1y' generated for fourteen (14) of the seventy-three (73) supports' inspected that were'dispositioned for re-work in Unit 1.
The. calculations show that those fourteen (14) supports, even if no. rework had been performed, meet all design criteria.~ ' Based on a statistical analysis performed by the Reliability and Risk Assessment Group,-it was concluded that, with a 95 percent statistical level of. confidence, greater than 99 percent of the Unit.1 HVACiduct supports' including the 256 supports not. inspected meet design criterir. and therefore are acceptable even if.no rework has bee per.
. Ref: ' Calculation 13-CC-ZS-010).
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formed for'the identified 73 supports.
II.
Analysis of Safety Implications
~ The condition described herein does not affect any safety-related HVAC 1 -
installations and will not prohibit any installation from performing its intended safety function during or af ter a Safe Shutdown Earthquake.
III.' Corrective Action Deficiencies: identified during the Unit I walkdown were documented by NoncGnformance Reports MA-2303, MC-2304, MG-2305, MR-2306, and MJ-2330.
The comprehensive walkdowns for Units 2 and 3 are currently being accomplished by Design Change Packages 2SM and 3CM-HA-030, HD-009 HF-014, HC-040, and HJ-035.
The resulting deficiencies will be analyzed and will be documented and corrected by issuance of Nonconformance Reports.. These Nonconformance Reports will cross-reference this DER.
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Finni R port.
' DER 84-13 Page Three-This corrective action plan will be complet'ed prior to Operating.
License in each unit.
-In' order to prevent recurrence of this condition.all engineering drawings for HVAC supports'have been revised to provide sufficient.
~ details to assure proper' installation and to prevent misinterpretation by TWC.
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