ML20132D841
| ML20132D841 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/09/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-33412-TDS, DER-85-07, DER-85-7, NUDOCS 8509300307 | |
| Download: ML20132D841 (6) | |
Text
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b Arizona Nuclear Power Project W
gg /g P.O. BOX 52034 e PHOENIX. ARIZONA 85072-2034
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September 9, 1985 '70//
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U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention:
Mr.
D.
F. Kirsch, Acting Director Division of Reactor Safety & Projects j' [;
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Subject:
Final Report - DER 85-07 A 50.55 (e) Evaluation Relating to CE Instrument Rack Deficiencies File:
85-019-026; D.4.33.2
Reference:
A) Telephone conversation between L. Miller and T.
Bradish on March 5, 1985 B) ANPP-32329, dated 4/8/85 (Interim Report)
C) ANPP-32654, dated 5/16/85 (Time Extension)
D) ANPP-32828, dated 6/13/85 (Time Extension)
E) ANPP-33013, dated 7/15/85 (Time Extension)
F) ANPP-33206, dated 8/13/85 (Time Extension)
G) Telephone conversation between C. Sorensen and T.
Siegfried on September 6, 1985
Dear Sir:
Attached is our final written report of the deficiency ref-erenced above, which has been determined Not Reportable under the requirements of 10CFR50.55 (e) and 10CFR21.
Very truly y"ours,
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h.
RLL-GRL E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/TPS/nj k
Attachment n.(.
cc:
See Page Two 8509300307 850909 PDR ADOCK 05000528 S
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Mr. D. F. Kirsch ANPP-33412-TDS/TPS DER 85-07 Page Two cc:
Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 J. G. Haynes D. B.
Karner W. E.
Ide D.
B. Fasnacht A. C. Rogers L. A. Souza D.
E.
Fowler T. D.
Shriver C. N. Russo J.
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Bynum J. M. Allen D. Canady A. C. Gehr G.A. Hierzer W. G. Bingham i
R. L. Patterson R. W. Welcher H. D. Taster D. R. hawkinson l-R.
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Zimmerman M. L. Clyde B. T.
Parker T. J. Bloom D. N.
Stover J. D. Houchen J.
E.
Kirby i
Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339
FINAL REPORT - DER 85-07 DEFICIENCY EVALUATION 50.55(e)
ARIZONA NUCLEAR POWER PROJECT (AhTP)
PVNGS UNITS 1, 2, 3 I.
Description of Deficiency A.
Incking Devices The fasteners of the instrument racks supplied by Combustion Engineering (13-NM-001) were not provided with locking devices per ASME Section III, paragraph NF-4725 on cmponents falling within the jurisdictional boundaries of ASME III (i.e., bolts for tubing clamps, valve support brackets, etc.). This locking device deficiency was first reported by CAR No. S-85-7, dated February 11, 1985, and also in CE letter V-CE-31943, dated February 15, 1985.
B.
Material Identification The bolt heads for the ASME Section III instrument rack components do not display the mnufacturer's identification symbol for ASFE and Quality Class "Q" installed bolts (Reference A-193/SA-193, paragraph S.5.1).
Some bolt heads do not display a proper ATSM/ASbE meerial designation; other bolt heads display two types of desig-nation such as two radial lines 90 degrees apart (_) ) and a "B8,"
making knowledge of the material type indeterminate.
Evaluation-A.
Iocking Devices The CE letter, V-CE-31943, contained detailed information and instructions for installing additional locking nuts to the existing nuts on the coded components (tubing clamps, isolation valve brackets, 3-way manifold support brackets and 3-way mnifolds) of the CE instru-ment racks. With the addition of these locking nuts, the munting of the coded cmponents meets the ASME Section III requirments.
The root cause of the locking device deficiency was that due to an oversight on ASME NF Boundary Identification, CE did not realize that the method of installation of the hardware nust comply with the NF section of the code in regard to the hardware vibration security during service and did not provide any special installation procedure for munting NF hardware on the instrument racks.
Canbustion Engineering has evaluated the locking device deficiency for reportability under the guidelines of 10CFR50.55(e) from both the structural and seismic qualification aspects. Structurally the CE instrument racks are installed either to the biological shield walls i
or floor slabs.
Neither installation contains any vibration sources, therefore, possibility that a significant number of bolts would loosen during normal operation is unlikely.
If some fasteners should become loose, the integrity of the system would not be cwwwtised since both the
Final Report DER 85-07 Page Two racks and the attached instruments are supported in a highly redundant manner (see Reference 1).
The seismic qualification (test reports Bechtel log no. N001-13.03-1036 and N001-13.01-868) of the complete rack assemblies was performed with the conponents in a tight condition. During these seismic tests the ASME cmponents were installed with only one nut on their fasteners. No failures of the ASME III NF components, supports or fasteners were reported during these seismic tests.
B.
Material Identification The Quality Class "Q" nounting hardware for electric equipment located on the CE transmitter racks was supplied by both CE Avery and Electro Mechanics. These fasteners are Itcm 31 of the CE Drawing No. 14273-510-011 (Bechtel log no. N001-13.01-728).
James C. White Company provided certification to ASME Code Section III Division I, Subsection NF and certified that the bolting material conformed to ASE-A193-B8. James C. White pro-cured the bolts from Century Fasteners. The James C. White pur-chase order to Century Fasteners imposed the requirement that the bolts be type 304 Stainless Steel with bolt heads marked "B-8" and certified to ASIM-A193-B8. Century Fasteners provided a certification to the James C. White Conpany purchase order, and marked on the front of the Certification of Compliance "B8 Stain-less ASTM-A193-B8." CE and James C. White both assumed that Century was the manufacturer of these bolts based on the Certi-l fication of Compliance. However, while researching the bolt mark-l ing probicm, Century Fasteners identified the fact that Bell Fasteners was the manufacturer.
Bell Fasteners reported to CE they are unable to retrieve their I
Quality Records on this order as their records were destroyed.
l Bell Fasteners did, however, state in a letter dated June 26, 1985 (Attachment to Reference 3) that the bolts conformed to ASIM-A193 l
specifications. CE conducted a test on five bolts that James C.
White had in stock from the original order. The results of the testing concluded that four bolts conformed to ASTM-A193-B8 AISI 304 specification and one bolt conformed to AS E-A193-B8M AISI 316 specification. These test results contradicted J. C.
khite's Certificate of Conformance that all the bolts conformed to ASIM-A193-B8 AISI 304 specifications.
Final Report DER 85-07 Page Three From a Materials point of view, all ASTM-A193 bolts have the same yield and tensile strength, therefore, a safety concern about the mechanical properties of the bolts does not exist.
The only material-related proble that does exist is that quality documentation is not available to validate the as-built conditions.
The James C. khite Company has also supplied the ASME Section III NF fastener material to the PVNGS project under Bechtel Specifi-cation 13-JM-712. The bolting material is to meet the require-ments of ASME III Division 1 Subsection NF and Code Case 1644-7.
The bolting material specified on the Jam 2s C. White drawings is ASIM-A307 Grade A except for one drawing (Bechtel log no. J712-9) which specifies S.A.E. Grade 2.
This material is equivalent to ASTM-A307 Grade A except for having a slightly higher yield strength (74 KSI vs. 60 KSI).
Based on previous bolting material investigations and the lack of any other material nonconformances concerning the James C. khite supplied material, this condition is evaluated as isolated to the CE instrument racks.
The probable cause of this material identification deficiency is poor workmanship, e.g., rcmoval of the bolt head designation by grinding, at either the third tier supplier (Century Fasteners) or the fourth tier supplier (Bell Fasteners). Evidently the original Bell Fasteners were identified with the ".J " mark and then star: ped with "B8."
The grinding was inccraplete and some bolt heads appear to be identified with both the ".] " and the "B8" markings.
II. Analysis of Safety Implications A.
Locking Devices Based on the evaluation in Section I, the locking device condition is not reportable under the provisions of 10CFR50.55(e) or 10CFR21 since if this condition were to rmain uncorrected it would not have presented a significant deficiency or substantial deficiency or substantial safety hazard.
B.
Material Identification The bolt materials supplied by the James C. khite Company to CE confonn to ASIM-A193 and have the same yield and tensile strength.
Final Report DER 85-07 Page Four Therefore, a safety concern about the mechanical properties of the bolt materials does not exist. It has been detemined that no significant deficiency or substantial safety hazard would be caused if this were left uncorrected, so it is not reportable under the requirments of 10CFR50.55(e) or 10CFR21.
III. Corrective Action A.
Ircking Devices locking nuts have been added to the CE instrument rack nounting bolts by DCPs Nos.10J-SB-050, 2SJ-SB-050, and 3CJ-SB-050.
These DCPs were based on infonnation provided by CE in letter V-CE-32236, dated April 11, 1985.
B.
Material Identification The fasteners identified as its 20 on CE Transmitter Rack Drawing 14273-510-011 (Bechtel log no. N001-13.01-728) are being rmoved and replaced with new fasteners procured to ASIM-A193-B8 requirments. The replacement is being imple-mented by the following documents:
Unit 1 - EER 85-RC-129 Unit 2 - EER 85-SI-123, SFR/NCR 2XX-5632 and NCR SJ-6025 Unit 3 - NCR SJ-6025 and NCR JC-13-20 Work is expected to be completed prior to fuel load for Units 2 and 3 and by the first outage for Unit 1.
A sample of ASME NF Boundaries indicated by CE documents will be checked to verify adequacy of material identification and proper requirments have been met. Discrepancies will be docu-mented by the appropriate deficiency document.
Bechtel will modify their receipt inspection checklist to perform sample verification of bolting material received to verify material meets code and specification requirments.
IV. References 1.
CE Lotter V-CE-32236, dated April 11, 1985 2.
CE Ictter V-CE-32514, dated June 13, 1985 3.
CE Letter V-CE-32697, dated August 5, 1985
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