ML20137Z161

Final Part 21 & Significant Deficiency Rept Re Ruskin Mfg Co Spring Closure Fire Dampers.Initially Reported on 841224. Dampers Reworked & in-place Testing Program to Identify Limiting Airflow Conditions Implemented

ML20137Z161
Person / Time
Site:	Hope Creek
Issue date:	11/21/1985
From:	Martin T Public Service Enterprise Group
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
REF-PT21-85-502-000 PT21-85-502, PT21-85-502-000, NUDOCS 8512110236
Download: ML20137Z161 (4)

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Public Service Electric and Gas Company 4 E. -

f . Thomas J. Martin 80 Park Plaza, Newark, NJ 07101 201430-8316 Mailing Address: P.O. Box 570, Newark, NJ 07101

- Vica President

. Engineering and Construction -

November 21, 1985

,3 Dr. . Thomas E. Murley, Administrator U. S. Nuclear Regulatory Commission

! Office of Inspection and Enforcement Region I 631 Park Avenue King.of Prussia, Pennsylvania 19406

Dear Dr. Murley:

I SIGNIFICANT CONSTRUCTION DEFICIENCY RUSKIN FIRE DAMPERS - MODEL NIBD-23

= HOPE CREEK GENERATING STATION On December 24, 1984, a verbal report was made to Region I, Office of Inspection and Enforcement representative, Mr. H.

. Kister, advising of a significant construction deficiency concerning the performance of spring closure fire dampers

. supplied by Ruskin Manufacturing Company. On January 25, April 1, July 23 and October 2, 1985, interim reports were sent to your office. The following final report.is.provided in accordance with 10CFR50.55(e).

Description of Deficiency Ruskin Manufacturing Company issued a 10CFR21 Report concern-ing the failure and/or reduced performance of spring closure ,

fire dampers which require closure under air flow conditions. l Ruskin reported that the test methods originally used to test dampers may not accurately reflect actual field installed

- conditions. Our Architect / Engineer and Constructor, Bechtel has evaluated all 692 fire dampers for applicability of the subject concern. These dampers were purchased variously as Q (for : seismic considerations), non-Q or F listed. The evaluation identified 81 dampers requiring modification.

Specific system / damper solutions have been developed based on vendor supplied and in place test results.

'8512110236 851121 PDR- ' ADOCK 05000354 S PDR 1 (0

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Dr. T. E. Murley 2 11/21/85 Safety Analysis Dampers 1GKD342, 343 and 345 were supplied by Ruskin and are installed in a three hour fire barrier at elevation 155' of the Hope Creek Diesel Generator / Control Building. This barrier separates redundant Control Building HVAC units lAVH403/400 and 1BVH403/400. These dampers are required to close under air flow conditions.

Had the reported condition gone undetected and uncorrected, failure of these dampers to close in the event of an unsuppressed fire in that location could adversely affect the Control Room HVAC units on both trains, thereby interrupting Control Room ventilation. Since the Control Room HVAC units are required for safe operation of the plant, we consider the deficient condition to be reportable in accordance with 10CFR50.55(e).

Corrective Action Your letter dated July 12, 1985, transmitting Inspection Report No. 85-24, directs that the nine (9) licensing related issues contained therein be resolved directly with your Office of Nuclear Reactor Regulation (NRR). Unresolved item No. 85-24-08 from that report specifically addresses Ruskin fire damper closure under air flow conditions. Accordingly, a complete description of our Ruskin Fir Damper Qualification Program and corresponding FSAR change will be submitted to NRR by December 2, 1985.

The below summary description of our corrective actions is pro-vided in accordance with 10CFR50.55(e).

Our review of the Ruskin damper issue was extensive and involved multiple aspects of potential corrective actions. The review included consideration of alternate dampers, damper modifications, replacement springs and latches, HVAC airflow modifications, administrative controls, fire area boundary redefinition, fire rated ductwork wraps, in-place testing programs, additional Ruskin testing programs, 'he use of coordinated electro-thermal link (ETL) closures on multi-section dampers, independent alarm systems, and automatic HVAC system shu'down. Each individual damper was evaluated against ths aesign airflows, taking all acceptance testing performed by Ruskin into account. The par-ticular solution chosen for each damper reflects the most appropriate resolution while considering the varying designs and operational parameters in each case.

Dr. T. E. Murley 3 11/21/85 The 81 Ruskin dampers were reworked with stronger listed springs, modified latch mechanism, and electro-thermal link closure coor-dination (for multi-section dampers). Following this modification work, PSE&G implemented an in-place testing program to identify limiting airflow conditions for specific damper applications.

Dampers were grouped according to airflow and size, with the worst-case damper in each group tested in-place under design airflow conditions.

Summary of damper resolution:

456 Acceptable as is.

37 Accepted based on in-place testing after spring and latch changes and ETL closure coordination.

104 Automatic HVAC shutdown.

56 Radwaste and Turbine Building Dampers.

22 Fire area redefinition and non-fire barrier dampers.

4 Duct wrap /3 hour barrier (variation of fire area redefinition).

6 Exemption Request (Unit 2 abandoned /no combustibles) 692 Total Additional explanatory details for the above categories will be

-included in our December 2, 1985, submittal to NRR.

Very truly yours,

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Dr. T. E.-Murley 4 11/21/85

.C Office of Inspection and Enforcement Division of' Reactor Construction Inspection.

Washington,.D. C. 20555 NRC' Resident Inspector - Hope Creek P.'O. Box 241-Hancocks Bridge, NJ 08038-

, Records. Center

-Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, GA 30339 t-4 I

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