ML20023D066

Requests That Region III Monitor CF Braun Activities in Independent Review of HVAC Sys at Facilities & That T Howard & s Marello Experience & Knowledge Be Utilized in Review Process.Util 820813 Ltr to CF Braun & Co Encl

ML20023D066
Person / Time
Site:	LaSalle, 05000000
Issue date:	08/13/1982
From:	Arlette Howard AFFILIATION NOT ASSIGNED
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20023A480	List: ML20023D030 ML20023D031 ML20023D032 ML20023D033 ML20023D034 ML20023D035 ML20023D036 ML20023D038 ML20023D039 ML20023D042 ML20023D046 ML20023D055 ML20023D066 ML20023D138 ML20023D140 ML20023D145 ML20023D146 ML20023D147 ML20023D172 ML20023D181 ML20023D188 ML20023D191 ML20023D196 ML20023D209 ML20023D213 ML20023D214
References
FOIA-82-366 NUDOCS 8305190179
Download: ML20023D066 (11)

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Acoress Reply to Post Othce Box 767 /T- ' ' *

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CNeago. Ilknois 60690 a

August 13, 1982 C.F. Braun & Co.

Power Division 1000 S. Fremont Avenue Alhambra, California 91802 Attn: Mr. George Boddeker

Subject:

Independent HVAC Review - LaSalle County Station

Dear Mr. Boddeker:

The United States Nuclear Regulatory Commission has requested that we have an independent HVAC review performed at our LaSalle County Station. Attachment A contains the special technical requirements by which the review must be performed. In general, however, it is intended tnat you verify that the HVAC installati.on is in accordance with the design.

You should provide us with a documented write-up outlining the plan by wnich you would perform this review. This plan should discuss your organization, qualifications, resumes of personnel, and any procedures and plans you would intend to use. I call your attention to the section of. Attachment A concerning the independence of review. Your eview should be performed with the guidance outlined therein, but you should feel free to suggest substitute forms of a similar. nature that C.F. Braun may have previously used.

LaSalle County Station Unit #1 is currently scheduled to complete 50% power. testing ab.out September 15, 1982. This schedule may l

, enange ba. sed on testing progress; however, we request you to supply L adequate support to this effort to provide a report by September 15 1982 I

tnat can be forwarded to the.NRC. All submittals would be provided to -

( Commonwea'lth Edison Company for direct forwarding to the NRC.

N 8.8. Stephenson ey hk 9//g,

, T.E. Watts 8.R. Shelton l B. Lee, Jr. LaSalle County Station C. Reed -

Project Engineering Manager L.0. DelGeorge C.W. Scnroeder R.E. VanDerway J.A. Harper R.J. Mazza - S&L D.C. Haan - S&L A.M. DeFusco - C.F. Braun A.J. Kempiak - C.F. Braun

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Attachment A N

LASALLE COUNTY STATION '

INDEPENDENT HVAC SYSTEMS REVIEW I. INTRODUCTION At the request of the Nuclear Regulatory Commission (NRC) staff, Commonwealth Edison Company (CECO) is to obtain the services of an outside consultant to conduct an independent review of the safety-related and seismically supported Heating, Ventilating and Air Conditioning (HVAC) systems at LaSalle. The consultant will verify that the HVAC installation is in accordance'with the design

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as described in Mr. C. Reed's August 4, 1982 letter to Mr. H.

Denton (Exhibit 1).

II'. SCOPE OF WORK ,

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Tne independent reviewer will review all seven LaSalle ,

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l safety-related HVAC systems.

- Control Room HVAC System (System Identification Code VC)

- Auxiliary Electric Equipment Room HVAC System (VE)

~ - Diesel-Generator Room Ventilation System (VD) .

- CSCS Equipment Area Cooling System (YY)

- Switch Gear Rooms Ventilation Systems (VX), except for the recirculation duct in the Auxiliary Building HVAC Equipment Room.

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Attachment A -

Page 2 j- 11. SCOPE OF WORK (continued)

- Portions of the Reactor Building Ve,ntilation System (VR): The

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, following parts of the reactor building ventilation system are safety-related: ,

- Supply air duct,between and including the secondary containment isolation dampers.and the duct penetration of the secondary containment boundary.

- Exhaust air duct between and including secondary containment isolation dampers, and the duct penetration of the secondary

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containmen't boundary.

- Those portions of the Standby Gas Treatment System SGTS (VG) installed by the Zack Co.

The independent reviewer will review the supports for all three ,

non-safety-related but seismic ~ ally supported systems:

- Primary Containment Ventilation System (VP)

- Primary Containment Purge System (VQ)

- Reactor Building Ventilating System (VR)

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Attachment A

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II. SCOPE OF WORK (continued)

The reviewer shall compare the Zack HVAC installation to the S&L design, review design changes, material, and testing done in the field up through the construction testing and whatever other aspects of these systems he deems necessary to:

" Verify that the HVAC installation is in accordance with the design. This will include, but not be limited to a review of the materials in. stalled, the field and shop welding on supports and ductwork, the operability of associated mechanical equipment, and significant design changes. The reviewer will be directed to independently verify the reliability and

adequacy of existing material.. structural and f.ield testing a'Iready performed;.and determine any, i additional testing or changes necessary.to reach the i

conclusion that the HVAC system fulfills its safety function."

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4 Attachment A

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'III. GENERAL Tne submittal should address the Quality Assurance *and Quality Control Plan that will be used to conduct the review.

All reviews should be done by appropriate procedures.

All personnel should be qualified for the, job they are required to

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perform. Suitable document ~ation should be available to demonstrate this qualification; e

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Attachment A Page 5 ,

IV. INDEPENDENCE

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Edison will make available to the independent revie'wer all dotuments requested by the independent reviewer needed to perform this review'. Any reports concerning this review shall be sent to Ceco who will in turn concurrently distribute the reports, unedited, to the NRC, S&L and internally within CECO. Prior review or editorial control of the written report by any of these parties is not permitte,d.

Any and all potential findings, shall be submitted in a timely manner to an internal finding review committee within the independent review organization composed of senior technical personnel with broad experience.in-technical management. This internal committee is to determine if the potential finding is accurate and has the potential for a safety concern. If the committee determines that the potential finding is accurate, but is i

i not a safety concern, it shall be properly documented, and submitted to Edison and dispositioned. Dispositioning may involve field correction, additional analyses or both, to ensure that

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required design margins are maintained.

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Attachment 2 Page 6 IV. INDEPENDENCE (continued) '

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If the finding is a potential safety concern, a second level internal committee will review those findings expeditiously and if the concern remains will notify Commonwealth Edison immediately.

Commonwealth Edison will properly document and disposition such findings (including taking proper action in accordance with the -

technical specifications), and notify the NRC. ,

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The individuals involved in this review shall complete Exhibit 2 and shall be free of substantive interest in Commonwealth Edison Compani or Zack. Examples of substantive interest are:

1. For full time personnel: any work experibnce in design, construction or quality assurance of the LaSalle County'

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Station, with Commonwealth Edison Company. or with the Zack Co.

cu'rrently or within the past five. years.

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2. For short term personnel: currently a.ctive on any other l

LaSalle County Station, Commonwealth Edison, or Zack Company l

l work.

L NOTE: No single short term person shall exceed 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per week and the cumulative effort of all such personnel snall not exceed 10% of the total project ef fort.

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I Attachment A Page 7 s

IV. INDEPENDENCE (continued)

3. An immed'iate f amfly member is employed by Commdgwealth Edison-or Zack Company or is engaged directly or indirectly in the design or constructio'n of the LaSalle County Station.

4 ., A cumulative ownership. and creditor interest in Commonwealth Edison or Zack Company Which exceeds 5% of their gross f amily annual income.

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Attachme'nt f

["g Ccmm:nw:cith Edison -

One Fast Natenat Plata. Chicago. Ithno s l

j Acoress Reply kr Post Office Boa 767 l Chicago. Illinois 60690 l

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August 4, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 , _

SUBJECT:

LaSalle County Station Units 1 and 2 '

Resolution of HVAC Concerns NRC Docket Nos. 50-373/374

Dear Mr. Denton:

Commonwealth Edison has taken steps to resolve the quality assurance documentation deficiences of the heating, ventilating and air conditioning

. (HVAC) system installed by the Zack Company at our LaSalle County Nuclear Power Plant throughout the course of the project. Nonconformance reports (NCR'S) issued by Zack have been reviewed and dispositioned by our engineering department and the architect-engineer, Sargent and Lundy.

Also extensive field inspections have been conducted by an independent testing agency Conam.- Additionally, materials have been tested in the fielci and. verified they met applicable material specifications. Based' on these investigations, Comonwealth Edison is confident that the HVAC system as installed can perform its design safety function.

However, to add another level of assurance, Edison will have an independent

. review of the safety-related portion-of the~ HVAC. system perfonned by consultants with expertise in HVAC system design, installation and'

. operation. The following general scope has. been. developed for the. review:

' I'. Verify that the HVAC instaliation is'in accordance with the design. This will include, but tot be limited to a review of the materials installed, the field and shop welding on supports

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and ductwork, the operability of associated. mechanical equipment, and significant design changes. The reviewer will be directed to independently verify the reliability and adequacy of existing material, structural and field testing clready perfonned; and determine any additional testing or changes necessary to reach the conclusion that the HVAC system fulfills its safety function.

2. Notify Comonwealth Edison immediately if a safety concern is discovered.

A more detailed scope will be developed after discussions with the consultants-and a report of their review will be submitted to the NRC by September 15, 1982. The consultants review will not be constrained by operational considerations.

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Page Two August 4, 1982 e

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In the event this verification program identifies any si deficiencies which would prevent the effected portion of the (s)gnif'icant HVAC sy's tem from fulfilling its safety-function, remedial action will be taken innediately in satisfaction of applicable technical specification

.'N requirements to restore adequate margin and assure the system it operable.

Operation beyond 50% pcier will not proceed until this assessment and any required remedial action has been completed.

To the extent deficiencies of lesser significance are identified, they will be do'cumented and reviewed with the NRC Staff and remedial action.

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/ if necessary, completed on a schedule agreed upon with the NRC Staff.

If there are any questions in this matter, please contact th,is office.

Very truly yours.

(['. . (2s s:<-k Cordell Reed -

Vice President ,

A cc: Mr. James G. Keppler

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.- Exhibit 2 LaSalle County-Station i Independent Design Review Agreement I - ---- - ----- --- -- - - - - - - - -

(print or type name) _

nereby agree that:

I will treat all information revealed to me in the course l'.

of my work on this project aE; confidential and will not disclose it to others not involved in the project except as directed by the Project Manager.

2. If I identify what I believe to be a potential finding having the potential for a significant safety impact, I will immediately notify the Project Manager for further evaluation. - - -

3. I will. notify the Project. Manager if during the term of.

this project I, or any member of my immedi' ate family (parents, spouse, children and grandchildren) acquire any.

financial. interest in Commonwealth Edison or Zack Company.

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l Signature . Date l

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