ML20137B792
| ML20137B792 | |
| Person / Time | |
|---|---|
| Issue date: | 12/06/1985 |
| From: | Merschoff E, Petrosino J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20137B728 | List: |
| References | |
| REF-QA-99901005 99901005-85-01, 99901005-85-1, NUDOCS 8601160078 | |
| Download: ML20137B792 (11) | |
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ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION 7/11-12/85 and INSPECTION NO.-
99901005/85-01 DATF(SI 8/5-9/R5 ON-SITE HOURS RR CORRESPONDENCE ADDRESS: Air Balance Incorporated Division of Reed National Corporation ATTN: Mr. S. B. Reed - President 260 North Elm Street Westfield, Massachusetts 01085 ORGANIZATIONAL CONTACT: Mr. Randy Wright - Assistant Product Manager TrirounNr NilMRrR-(d10 R@ QR71 PRINCIPAL PRODUCT: Fire Dampers NUCLEAR INDUSTRY ACTIVITY: Approximately 2%. Current in-house nuclear orders: Millstone 3, Braidwood, St. Lucie, Vogtle, Shearon Harris, and Robinson.
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ASSIGNED INSPECTOR:
.t<ug / -f /,M 4$7Fs 7 J. -J.j Petrosino, Reactive Inspection Section (RIS) ' Date
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OTHERINSPECTOR(S):
E. L. Burns, Brookhaven National Laboratory APPROVED BY:
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E. W. Merschof R Chief, RIS, Vendor Program Pranch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and Appendix B of 10 CFR Part 50.
B.
SCOPE:
(1) Obtain information in regard to curtain type fire damper deficiencies, (2) evaluate the Air Balance quality assurance program for adequacy and implementation of applicable requirements.
PLANT SITE APPLICABILITY: Beaver Valley 1 & 2 (50-334/412); Braidwood 1 & 2 (50-456/457); Clinton (50-461); Comanche Peak 1 & 2 (50-445/446); D.C. Cook 1 & 2 (50-315/316); Crystal River (50-302); Davis Besse (50-346);
B601160078 860110 PDR GA999 ENVAIRB 99901005 PDR
c ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO.-
99901005/85-01 RESULTS:
PAGE 2 of 11 PLANT SITE APPLICABILITY:
(continued) Duane Arnold (50-331); Farley 1 & 2 (50-348/364); Fitzpatrick (50-333); Enrico Fermi 2 (50-341); Grand Gulf 1 & 2 (50-416/417); Haddam Neck (50-213); Indian Point 2 & 3 (50-247/286); Kewaunee (50-305); Limerick 1 & 2 (50-353/352); Millstone 1, 2 & 3 (50-245/336/423);
Monticello (50-263); Nine Mile Point 1 & 2 (50-220/410); Oyster Creek (50-219);
Palisades (50-255); Peach Bottom 2 & 3 (50-277/278); Perry 1 & 2 (50-440/441);
Pilgrim 1 (50-293); Point Beach 1 & 2 (50-266/301); Quad Cities 1 & 2 (50-254/265); Rancho Seco 1 (50-312); River Bend 1 & 2 (50-458/459); Robinson 2 (50-261); San Onofre 1, 2 & 3 (50-206/361/362); Seabrook 1 & 2 (50-443/444);
Shoreham (50-322); St. Lucie 1 & 2 (50-335/389); Summer (50-395); Susquehanna 1 & 2 (50-281/387); Three Mile Island 1 & 2 (50-289/320); Vermont Yankee (50-271); Vogtle 1 & 2 (50-424/425); Waterford 3 (50-382); Watts Bar 1 & 2 (59-390/391); Washington Nuclear 1, 2 & 3 (50-460/397/508).
A.
INSPECTION ISSUES:
1.
Decermine if failures of curtain type fire dampers to close under certain flow conditions, as reported by Ruskin Manufacturing Company (RMC), apply to Air Balance (ABI) supplied fire dampers.
2.
Review the ABI quality assurance program for adequacy and impl'ementation in regard to NRC regulations.
B.
INSPECTION FINDINGS:
1.
The failure of fire dampers to close under certain flow conditions is applicable to the ABI curtain type fire damper. Although ABI does do some testing of curtain type fire dampers under duct flow conditions, ABI's Assistant Product Manager stated that the ratings provided on the specification sheets are not guaranteed and therefore it is possible that damper closure may not occur under all duct flow conditions. This issue also affects other similar designed curtain type fire damper manufacturers, as discussed below.
2.
The ABI quality assurance manual (QAM) adequately addresses all 18 criteria of Appendix B to 10 CFR Part 50, and ANSI N45.2, as required.
However, the QA program implementation is inadequate in several areas as discussed below. A lack of ABI management support for the QA program was also apparent.
1
a ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO.-
99901005/85-01 RESULTS:
PAGF"5 of 11
_v C.
SUPPLEMENTARY INFORMATION:
1.
An NRC inspection at the Ruskin Manufacturing Company (RMC) offices in February 1985 in conjunction with discussions with personnel from RMC, Air Balance, Incorporated (ABI), and Underwriters Laboratories indicates that both ABI and RMC curtain type (CT) fire dampers s
(FD) could fail to close under certain flow corditions. The failure frequency of the CT fire dampers to close under flow conditions was determined to be relative to one or more of the following factors:
a.
Size of the individual fire damper - As the size of the fire damper increased, the flow velocity at which it could close decreased.
b.
Velocity of air flow - The test reports indicated more closure difficulties under higher flow velocities.
c.
Horizontally installed dampers - RMC's horizontal damper test report results indicated lower flow velocity rates at which the CT-FD's would fail to close, than the vertically s
installed dampers.
d.
' Negator springs - Curtain type fire dampers witho$c any negator sp:ings to assist the closure would be' the most susceptible to failures during closure under flow?
s However, potential failures of the curtain type fire' dampers to close under certain flow ccnditions cannot be limited to just ABI or RMC.
This appears to be a generic issue which co'uld affect any manufacturers' similarly desigr.ed curtain type fire damper, which will be used in nuclea[ safyty related applications.
Currently, there are no mandatory industry w)de functional test requirements to assure that the curtain type fire dampers will operate under specific flow conditions.
s There is one industry t'esting requirement with which all fire damper maoufacturers comply.
It is the Underwriters Laboratories Standard T
(6L), Number 555, " Standard for Fire Dampers and Ceiling Dampers".
UL-555 testing methods are implemented to verify the fire hour
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION Nn
- Q4401005/85-01 RESULTS:
PAGE 4 of 11
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rating of specific dampers. The tests determine the acceptability of fire damper assemblies for use where fire resistance of a s(
specified duration of time is required.
s
'c s
Section 1.6 of UL-555 states, in part:
" Closing reliability of fire dampers...is evaluated on the basis that... ventilating systems are automatically shut down when a fire occurs...
Therefore, the ratings are applicable to fire dampers...
installed in systems where air movement is effectively stopped at the start of a fire."
Therefore, the failure of fire dampers to close under certain flow conditions may possibly affect all nuclear plant systems, if the specific system design does not require air movement to be stopped at the start of a fire.
2.
A total of two violations and several nonconformances were identified within the ABI quality assurance program.
Implementation of the ABI quality assurance program has not been adequately performed.
The ABI QA Manager appears to be the only person within the ABI organization that is implementing or cognizant of the quality assurance program.
D.
VIOLATIONS:
1.
Contrary to Section 21.21 of 10 CFR Part 21, appropriate procedures to evaluate deviations or inform the licensee of the deviation had not been adopted by ABI (85-01-01).
2.
Contrary to Section 21.6 of 10 CFR Part 21, cooies of 10 CFR Part 21 or an explanatory notice describing the regulations /
procedures was not posted (85-01-02).
E.
NONCONFORMANCES:
1.
Contrary to Criterion I of Appendix B to 10 CFR Part 50, and ANSI N45.2. the ABI QA Manager does not have adequate organizational freedom or sufficient independence from cost and schedule, and the QAM organizational chart does not accurately depict the current organization as indicated by the following examples:
a.
The QA Manager is also the ABI Purchasing Agent for the entire manufacturing facility at Wrens, Georgia (85-01-03).
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO -
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PAGE 5 of 11 b.
The QA Manager reports to the Wrens, Georgia, Plant Manager approximately 90% of the time while acting as the Wrens facility Purchasing Agent (85-01-03).
c.
Annual performance evaluation of the QA Manager is performed by the Wrens facility Plant Manager (85-01-03).
d.
Only seven out of eleven management positions indicated on the organizational chart, contained in the ABI-QAM, had their responsibilities delineated (85-01-04).
e.
Two ABI management personnel had job titles for which responsibilities and authorities were not delineated. These titles were Vice President-Engineering and Assistant Product Manager (85-01-04).
2.
Contrary to Criterion II.of Appendix B to 10' CFR Part 50, and Section 2.4 of the ABI-QAM (85-01-05):
a.
The ABI President did not annually review and approve the ABI QA program.
b.
The management of other organizations participating in the QA program did not review their applicable part of the program for status and adequacy.
c.
ABI did not perform QA program indoctrination for any management personnel at either facility.
3.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Sections 7.2.4 and 11.4 of the ABI-QAM (85-01-06):
a.
ABI Project Engineering has not performed its function of issuing the ABI " shop traveler" in accordance with the ABI-QAM.
b.
ABI QA/QC fire damper final inspection procedures had not been issued for use by inspection personnel.
4.
Contrary to Criteria X and XVII of Appendix B to 10 CFR Part 50 and Sections 11.1 cnd 11.3 of the ABI-GAM (85-01-07):
a.
No QA/QC in-process inspection activities for any nuclear orders had been documented.
1
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO.-
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PAGE 6 of 11 b.
No in-process sampling inspections, based on MIL-STD-105D had been implemented or documented for any ABI nuclear order.
5.
Contrary to Criteria XV and XVI of Appendix B to 10 CFR Part 50 and Section 16.1 of the ABI QAM (85-01-08):
a.
QA/QC hold tags are not utilized for control of nonconforming items as observed on a in-process nuclear order.
b.
QA/QC hold tags have not been issued to QA/QC inspection personnel, nor could any ABI hold tags be produced for the NRC inspectors.
c.
No ABI nonconformance report log had been established to log nonconformance reports.
6.
Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and Section 19.1 of the ABI-QAM, the annually required QA program audits have been performed only once in the last five years, at the Wrens, Georgia, facility (85-01-09).
7.
Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and Sections 8.1 and 8.2 of the ABI-QAM, an accurate and current approved vendors list was not maintained (85-01-10).
F.
OTHER FINDINGS OR COMMENTS:
1.
Quality Assurance Program It was obser.ved that the ABI QA Manager is stationed at the Wrens, Georgia, facility where hi aain duties are as the Purchasing Agent. Discussions indicated that 90% of his time was spent as Purchasing Agent and the remainder as QA Manager. Additionally, the QA Manager functions as the QC inspector at Wrens. However, it was learned that annual performance evaluations for the QA Manager, for possible salary increases, are completed by the ABI manufacturing Plant Manager.
A major portion of the responsi-bilities of the Purchasing Agent is procurement of manufacturing 4
ORGANIZATION: AIR BALANCE INCORPORATF' WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO.-
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PAGE 7 of 11 naterials, equipment, services and the scheduling of production, which renders the in Manager insufficiently independent from cost and schedule.
Since the QA Manager and Purchasing Agent functions are performed by the same person a conflict is apparent.
A review of the QA Manual indicates it adequately addresses Appendix B requirements.
However, implementation and updating of certain administrative portions of the manual is necessary for compliance to the regulations.
Discussions with ABI personnel in conjunction with the QAM review appeared to indicate that other than the QA Manager, no ABI personnel are cognizant of the QA program or their responsibilities.
This was evidenced by:
a.
Lack of adequate records of management review of the QA program.
b.
Personnel lack of familiarity with their QA program responsibilities.
c.
Several QA program implementation deficiencies.
It was observed that numerous quality related functions assigned throughout the QAM were not being performed at all.
Personnel were querried concerning the amount or type of 0A program indoctrination or training that they had received.
It was concluded that this area of personnel introduction to the ABI QA program has not been accomplished.
QA personnel do not become involved with ABI nuclear engineering or design activities until the documents are sent to Wrens, Georgia, for fabrication of the products.
2.
Audits and Approved Vendors List ABI corporate headquarters personnel indicated that no internal audits are performed on the Wrens, Georgia, manufacturing facility and subsequent record reviews cavealed that in a five year period only one audit was performed.
However, annual audits have been performed at the Westfield offices.
Corrective actions identified on these audits are, in part, unresolved.
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION Hn - 99901005/85-01 RESULTS:
PAGE 8 of 11 The Approved Vendors List (AVL), which is a part of the QAM, was found to be inconsistent in regard to the requirements for listing the vendors on the AVL.
Section 8.1 of the QAM indicated that vendors would be placed on the AVL after an audit of their QA program.
However, three out of a sample of eight vendors on the AVL did not have a QA program.
3.
Plant Tours A facility tour on July 11, 1985 at the corporate offices in Westfield, Massachusetts, and a manufacturing plant tour on.
August 5, 1985 at the Wrens, Georgia, facility were conducted.
Several deviations from the ABI QA program were observed.
The manufacturing process of nuclear fire dampers is controlled in part by the use of a shop traveler, which accompanies a shop
" cut sheet" print out, which delineates all measurements and
" cut" locations. The shop traveler is required to be generated by the Project Engineerir:g department with QA review for possible modifications and approval.
However, the shop travelers were found to be generated and approved by the QA Manager.
4.
Design and Testing The ABI nuclear application fire damper is a curtain-type device identified by the model number prefix 319. The Assistant Product Manager stated that the model 319 is a modified version of the 1-1/2 hour fire-rated commercial damper model 119, which has been enhanced with additional rivets, a change in sill angle, and the addition of a nullion strip in order to achieve a 3-hour fire rating. A review of engineering drawing control sheet 10-1822 dated May 11, 1978, revealed that no modifications have been made to the model 319 basic damper since its original adaptation from tne model 119 damper. The model 319 fire damper is equipped with either an electro-thermal-link (ETL) or a fusible link, depending on damper size, for ensuring closure. ABI personnel stated that no complaints or reports of malfunction had been received concerning performance of this product. However, the Assistant Product Manager did disclose that ratings provided on model 319 (marketing) specification sheets are 'not guaranteed,' and there-fore it is possible that damper closure may not occur in all applications under all duct flow conditions. Testing of this damper is fre~quently conducted, primarily for satisfying procurement contract requirements, and as a result considerable free area, flow, and leakage data is available for various model 319 sizes for use in
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION 44401005/R5-01 RESULTS:
PAGE 9 of 11 NO the horizontal as well as vertical application.
Since the ABI laboratory facilities are not equipped to perform large-scale, elevated-velocity flow evaluations, damper testing for licensee acceptance is typically conducted by a subcontractor, American Warming & Ventilation Company. A review of a typical performance test conducted for Pullman Sheet Metal Works on behalf of CP&L/Shearon Harris dated November 1984, revealed the use of a comprehensive procedure addressing static pressure, total air flow velocity, maximum allowable leakage, and a requirement for three (3) consecutive closures under maximum simulated conditions.
From the review of this document it was apparent that under certain conditions, the model 319 fire damper will perform as required.
However, there was no documentation correlating the test conditions to operating conditions.
It.was also noted that ABI has made extensive efforts for ensuring proper damper installation and for long-term operability verification by the end user.
For example, ETL instructions, which accompany all dampers so equipped, provide inspection notes and precautions for installation which are intended primarily to prevent dempor failure due to human error.
In addition, a review of correspondence from ABI to Bechtel Corporation, on behalf of FP&L/ Turkey Point Units 3 & 4, dated December 30, 1982 provided recommendations for damper installation, annual inspection, and periodic maintenance.
5.
10 CFR Part 21 Observations of the ABI bulletin boards to assure that adequate 10.CFR Part 21 posting was accomplished, revealed that only a modified version of Section 206 of the Energy Reorganization Act of 1974 was posted.
Subsequent discussions with ABI personnel indicated that they were not familiar with the requirements of 10 CFR Part 21.
Section 21.21 of Part 21 was discussed, since it concerns the evaluation of deviations and notification requirements. The personnel were also not cognizant of these requirements. Current copies of Part 21 and Section 206 were provided to both API locations. Section 21.21 was briefly explained by the NRC inspectors.
No procedures to evaluate deviations and notify the end users had been generated or adopted by ABI.
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO -
99901005/85-01 RESULTS:
PAGE 10 of 11 Concern was expressed to ABI that correspondence with licensees may not be adequately screened for potential 10 CFR Part 21 defects, which are identified to ABI through their normal customer service channels.
During customer document package reviews it was revealed that many of the licensees had not imposed Part 21 upon ABI for the manufacture of fire dampers. However, Quality Air Design P0
- 22269, dated October 28, 1983 and PASNY P0 Specification dated January 16, 1985 imposed Part 21 on ABI, but ABI did not impose Part 21 on their suppliers.
G.
PERSONS CONTACTED:
W. Jennings, Vice President - Engineering (Westfield)
R. Wright, Assistant Product Manager (Westfield)
A. Ondik, Wrens, Georgia Plant Manager M. Bekanon, Purchasing Agent and 0A Manager (Wrens)
H.
DOCUMENTS EXAMINED:
The documents listed below were reviewed by the inspectors to the extent necessary to satisfy the objectives of the inspection.
1.
Quality Assurance Documents QA Manual, Revision 1, 7/15/82 QA-QC audit report letter to ABI, 6/25/85 ABI audit of Elsie Manufacturing Co., 2/4/85 ABI audit of S&R Products Co., 2/5/85 ABI audit of Law Engineering / Testing, 2/22/85 Internal ABI audit report - manufacturing, 2/11/81 Stone & Webster audit report letter, 6/17/81 Internal ABI audit report (QA Manager to R. Wright /W. Jennings, 2/16/85 ABI audit letter to Law Engineering / Testing, 2/28/85 2.
Procurement and Associated Correspondence PASNY P0 Specification No. [[::JAF-85021-01|JAF-85021-01]],1/16/85 Pullman P0 to Addco (St. Lucie) #32926, 1/26/83 ABI P0 to Pullman (St. Lucie) #44613, 12/31/82 (N942862)
ABI P0 to Addco (St. Lucie) #46915, 3/11/83 (N944629)
Pullman P0 to ABI (St. Lucie) #12948, 3/4/85 (N964856)
Pullman P0 to ABI (Braidwood) #36240, 10/16/84 IDM-Pullman to Braidwood, 10/30/84 (N961001/1002) t J
ORGANIZATION: AIR BALANCE INCORPORATED WESTFIELD, MASSACHUSETTS REPORT INSPECTION NO.-
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PAGE 11 of 11-Braidwood P0 to ABI, 3/1/85 (N964400)
Pullman to Addco P0, 11/19/84 (N965777)
Braidwood related drawing, BRCC-507, 6/16/84 Crystal River P0 Specification, SP5833, 2/4/77 PEC procurement report letter of ABI-QAM, 6/14/85 FP&L P0, F9025676D, 9/5/84 ABI material receipt of Edgcomb Metals, P05756, 7/23/81 CMTR, Edgcomb, T16579, 8/5/81 ABI P0 to Edgcomb, 5756, 7/17/81 CMTR Edgcomb, V18257, 9/4/81 ABI P0 to Edgcomb, 5852,8/17/81(V18257)
ABI P0 to Edgcomb, 5814, 8/5/81 CMTR, Edgcomb, T16385, 8/19/81 ABI P0 to Edgcomb, 5754, 7/17/81 Pullman P0 to ABI, 35569, 6/18/85 (Shearon Harris)
Pullman P0 to ABI, 36240, 10/16/84 (Braidwood)
Pullman P0 to ABI, 35569, 11/14/84 (Shearon Harris)
QAD P0 to ABI, 22269,10/28/83 (River Bend)
IDM R. Wright to M. Bekanon (N950686),10/18/83, specifies Part 21 applies ABI P0 to Edgcomb, 10933, 6/6/85, Part 21 imposed Pullman P0 to ABI,12948, 3/4/85 (St. Lucie) 4 3.
Other Documents ABI Drawing 21285-1, 2/26/85, 319 ALV-UL design ABI Drawing 21285-5, 2/26/84, fire damper schedule Cygna Letter to ABI, 85021-011,3/14/85, seismic report Ebasco Seismic Test Report #J0 0801, 4/29/83, Chin Shan Nuclear Gage Lab certification of gage, #1682002, 9/28/84 Gage Lab certification of meter, #1t,82001, 9/10/85 ABI P0 to Gage Lab, Caliper #1682003 recal., 7/15/85 Purchasing Record Log / Card Catalog, PASNY #85-866 ABI Drawing Control Sheet, Model 319,5/11/78 Closure Tests for Horizontal & Vertical Damper Model #319 S&R/ABI Instructions for ETL Installation ABI letter to Bechtel, 12/82, Turkey Point ABI Drawing, DSK-12618, Model #119, Free Area Chart, 5/24/83 ABI Drawing, C-11097, Model #119 Blade Chart, 2/10/77 Underwriters Laboratory Standard #UL-555, oated 5/14/79 (6/1/79)