ML20198D152

Responds to 860207 Request for Review of Prior Violation & Conclusions in Insp Repts 50-254/85-27 & 50-265/85-30 Re Ruskin Mfg Co Part 21 Rept Concerning Fire Dampers Failing to Close.Violation Should Be Withdrawn

ML20198D152
Person / Time
Site:	Quad Cities
Issue date:	05/15/1986
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
REF-PT21-86 NUDOCS 8605230167
Download: ML20198D152 (2)

See also: IR 05000254/1985027

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MAY 151986

Docket No. 50-254

Docket No. 50-265

Commonwealth Edison Company

ATTN: Mr. Cordell Reed

Vice President

Post Office Box 767

Chicago, IL 60690

Gentlemen:

This is in response to your letter of February 7,1986 which requested a

review of a prior violation and our conclusions as discussed in NRC Region III

Inspection Reports No. 50-254/85027; 50-265/85030. The specific violation

related to a Part 21 issued by Ruskin Manufacturing Company concerning fire

dampers that may fail to close under flow conditions. It appeared that one

damper that was required to close under flow conditions was not tested for

operability as recommended by Ruskin.

We have carefully evaluated the additional information that was provided in

your response of February 7, 1986. We were not aware that the pre-fire

procedure contains a statement regarding shutdown of the HVAC system, thus

not requiring the damper to close under flow conditions. Consequently, we

have concluded that the violation should be withdrawn. We will adjust our

records accordingly.

While we agree that the fire protection function of such dampers is not safety

related in the strictest definition of safety related, they do perform a

function which is vital to the preservation of plant safe shutdown capability.

Further, we take exception to your position that 10 CFR Part 21 evaluations are

required only for safety related equipment. As stated in 10 CFR Part 21

Section 21.21(b)(1), "A Director or responsible official subject to the

regulations of this part, or a designated person, shall notify the Commission

when he obtains information reasonably indicating a failure to comply or a

defect affecting . . . a basic component that is within the organization's

responsibility . . . ." Section 21.3 defines basic component, in part, as a

plant structure, system, or component, or part thereof necessary to assure the

capability to shut down the reactor and maintain it in a safe shutdown

condition.

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Commonwealth Edison Company 2 MAY 151986

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In the future, we expect you will complete 10 CFR Part 21 reviews in compliance

with the above.

Sincerely,

JQcisipt Eliu:4 C.5. f 2 2 ^ -

Charles E. Norelius, Director

Division of Reactor Projects

cc: D. L. Farrar, Director

of Nuclear Licensing

N. Kalivianakis, Plant Manager

DCS/RSB (RIDS)

Licensing Fee Management Branch

Resident Inspector, RIII

-Phyllis Dunton, Attorney

General's Office, Environmental

Control Division

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