ML20127H309

Responds to Re Ruskin Mfg Co 841106 Part 21 Rept & Associated CPC 841106 10CFR50.55 Rept.Review of Files Revealed No Direct Relationship Between Problems Identified by D Dartey or E Kent & Problems in Part 21 Rept

ML20127H309
Person / Time
Site:	Midland
Issue date:	05/17/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
References
NUDOCS 8505210268
Download: ML20127H309 (5)

Text

~

• ' . -l) m fa .

1E01 MAY y 7 y995 Billie Pirner Garde.

Citizens Clinic Director Government Accour,tability Project

.1555 Connecticut Avenue, N.W. Suite 202 Washington, D. C. 20036

Dear Ms. Garde:

In . response to your letter of January 7,1985, regarding a Part 21 Report filed by Ruskin Manufacturing Company on November 6, 1984 and an associated 10 CFR 50.55(e) report filed by the Consumer's Power Company on November 27, 1984, we have reviewed our files and find no direct relationship to the problems identified by Mr. Dean Dartey or Mr. Earl Kent and those problems identified in the Puskin's Part 21 report.

. Based upon a review of Mr. Dartey's original statements to the NRC and his affidavits and depositions to the NRC and those statements, affidavits and depositions of others associated with the Zack Corporation, the only fire damper concerns identified dealt with quality control during receipt and installation. These concerns included traceability of fire damper serial numbers, the adequacy of Zack procedures, specific instructions and methods used for field installation and repairs, and discrepancies between Bechtel material specifications for housing sheet metal thickness (gauge) and that supplied by Ruskin. These concerns were related to quality control during

. installation of the HVAC system and not.to the design, functional testing, and operations of the HVAC systems. The staff also re-reviewed Mr. Kent's  ;

statements, affidavits and depositions and could find no reference to fire

' dampers'at Midland. Mr. Kent's concerns deal.t with onsite welding associated 7

principally with small bore piping and piping supports.

These Midland concerns were directly related to the Zack Corporation problems

( .and were site specific rather than a generic Ruskin equipment problem.: Each concern was documented and addressed in an inspection report.

Although we believe the concerns identified by Mr. Dartey and others were r specific to the Zack Corporation and their work at Midland, LaSalle and Clinton and that those concerns have been properly pursued and resolved, we have found a continuation of identified problems in the area of fire dampers.

This is evidenced by the number of problems and deficiencies identified in

! .Part -50.55(e), Part 21 and Licensee Event Reports, and by the NRC fire i

protection inspections. These are being pursued both at the specific sites and at the generic level with the Program Offices.

Enclosure 1 provides answers to your specific questions. Enclosure 2 provides j

a listing of Ruskin Part 21 Reports for your information.

l 8505210268 850517 PDR ADOCK 05000329 S PDR

, ik E

[;.

MAY 1 7 1985 Billie Pirner Garde 2 I apologize for.the tardiness of this reply and hope that the information provided is' responsive to your concerns.

Sincerely,. -

Original signed by J m* G G. Keppler James G. Keppler Regional Administrator

Enclosures:

1. Answers to Ms. Garde's Specific Questions 2.. Part 21 Reports issued

.by' Ruskin bec w/encls.

W. J. Dircks, EDO

-D. G. Eisenhut, D/DL Ben Hayes, 01 DMB/ Document Control Desk (RIDS)

RIII R RIII RIII RIII R II RI,IJ/

Tambling/pg . n N as S y

ssard

)

Dayis

%f ehm -

Gl' KEpp]er 05/03/85 -

)$% J//) c]I4 6 g

ENCLOSURE 1 Answers to Ms. Garde's Specific Questions

1. What model types are included in the Part 21 notification?

Date of Model Number Part 21 Of Damper Report Involved Type November 6, 1984 180-21 Positive closure, curtain type with 1 hours fire rating IBD-23 Same as IBD-21 but with three hour fire rating NIBD-23 Positive closure, curtain type, with three hour fire rating for Nuclear application (seismically qualified)

2. What action, if any, was taken in the 1979 through 1982 time frame to determine whether the problems ultimately discovered in operation at Palo Verde were a potential?

No action was taken nor was any action required.

Problems identified in the Part 21 Report associated with Palo Verde dealt with the functional testing of fire dampers under flow conditions. .

The dampers would not close under flow conditions. In the time frame of 1979 through 1982, Midland was still in the fabrication, installation and repair phase of HVAC construction and any functional testing would have been limited to manual activation of the shutters in fir 3 dampers and static leakage testing of duct seals.

The reported problems at Palo Verde were related to the fire damper design when the dampers were subjected to flow conditions. In vertically mounted dampers the electro / thermal linkage was interfering with the complete closure of the shutters. In horizontally mounted dampers, the negator springs were not strong enough without gravity assist to ensure shutter closure.

Since the problems identified at Midland and with the Zack Corporation were associated with breakdowns in the quality assurance programs with site HVAC installation and were not associated with fire damper design, the two problems are not related.

I

3. What notification, if any, did Region III give to other Regional NRC offices, or to the operators and constructors of nuclear power plants?

At the time of the original HVAC problems identified at Midland and subsequently associated with the Zack Corporation, it was determined that they applied only to those sites where the Zack Corporation was a subcontractor (Midland, LaSalle and Clinton) and the region assured -

itself that the effccted licensees were notified.

4. What action was taken by Region III or the vendor inspection branch to determine when Ruskin or the Zack Corporation decided to notify the NRC about the problems known to both corporations for several years?

As to the problems known to both corporations for several years, we are not aware of any Zack related problems that would require a Part 21 report by Ruskin or further action by Region III and the Vendor Branch.

As part of a routine policy, the Vendor Branch has conducted three inspections of Ruskin. Each of these inspections was a followup to Part 21 reports issues by Ruskin.

5. Has this matter, or will it be, referred to Office of Investigations

("0I") for investigation into the four year delay of a Part 21 notification?

The matter referred to in your letter has not been referred to 01 nor do we plan to refer it.

6. What efforts have been taken to issue an Information Bulletin regarding the Ruskin Fire Dampers?

On October 21, 1983, the NRC did issue IE Information Notice Number 83-69 describing three potentially generic problems with fire dampers, including dampers not installed in accordance with drawing, one and one half hour rated dampers installed where three hours rated dampers were required, and-dampers located in the ducts in a room and not within the fire wall penetrations.

7. What program is in place, if any, to determine the generic implications of allegations given to the NRC?

l There are numerous policy statements and procedures within the NRC regarding l feedback on potentially generic issues and inspection findings. These .

include general policies established in the 2500 series I&E Manual Chapters for the reactor inspection program, IE Chapter 0970-Potentially Generic l

Questions Identified by Regional Offices, IE Chapter 720 for bulletins and

! information notices, Inspection Procedures 92715 and 92716 for Part 21 l Reports, Inspection Procedure 90711 for Nonroutine Event Review, Board Notification policy, and NRC Manual Chapter 0517-Management of Allegations.

! Review of allegations for generic implications fall within these overall i

programs.

L 2

Enclosure 2 Part 21 Reports Issued by Ruskin January 21, 1980 Ruskin issued Part 21 Report on an Model NIBD 23, Vertical Curtain Type Fire Damper. Problem was identified by Bechtel to Ruskin on December 18, 1979. Dampers were being cycle tested prior to installation at Callaway. Some of the negator type springs had slipped out of the spring holding slot in the spring bracket. Ruskin identified 15 nuclear sites that had these dampers. .In Region III this included Quad Cities, Zimmer, Callaway, Midland, Perry.and D. C. Cook. Ruskin sent notices and proposed corrective action to each purchaser.

March 17, 1980 Ruskin issued a followup letter to the January 21, 1980 letter indicating problems with the original fix and method of-hand cycling the dampers.

April 4, 1980- Ruskin issued a followup letter to the January 21, 1980, and March 17, 1980, letters. They provided an alternate fix to attaching the damper spring and a fi'x.to cycling problems to prevent back up.

May 10, 1983 Ruskin issued a Part 21 report on Models CBS-7 and CBS-8 backdraft dampers regarding their seismic report No. 1018. This was identified by Ebasco Services at Harris. Ruskin notified 12 nuclear customers. In Region III this includes Zimmer. 2 November 11, 1984 Ruskin issued a Part 21 report on Models IBD-21, 180-23 and NIBD-23 fire dampers (interlocking blade). The problem was identified by the Waldinger i Corporation at Palo Verde and involved a failure of the dampers to cycle under normal direct pressure flow.

lL The problem was identified to a difference between face mounted and direct mounted damper. Face mounted dampers required higher static pressure to operate than those mounted in th- duct work. Approximately 42 nuclear sites have been supplied this type dampers. In Region III this includes Clinton, Midland, LaSalle, Zimmer, Quad-Cities, Marble Hill, l

Perry, Monticello, D. C. Cook, Duane Arnold, tlyron, Braidwood, Calloway, Davis-Besse and Zion.

l-

_._ . - -