ML20065D034
| ML20065D034 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/15/1982 |
| From: | Kempiak A C.F. BRAUN & CO. |
| To: | |
| Shared Package | |
| ML20065D025 | List: |
| References | |
| NUDOCS 8209240373 | |
| Download: ML20065D034 (17) | |
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V COMMONWEALTil EDISON COMPANY LA SALLE' COUNTY STATION CllICAGO, ILLINOI$
INDEPENDENT llVAC REVIEW INTERIM REPORT PROJECT 6356-N a
C F BRAUN 6 C0 AlliAMBRA, CALIFORNIA SEPTEMBER 15, 1982
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Page 1 of 11 Commonwealth Edison Co INDEPENDENT HVAC REVIEW Project 6356-N INTERIM REPORT
( La Salle .,
This interim report contain; the preliminary results of the Independent HVAC Review of the Commonwealth Edison La Salle Station Unit 1 Nuclear Power Plant as performed by C F Braun.
As C F Braun Project Manager for this review, I state that C F Braun has maintained independence, has not been coerced by any of the parties involved and has had complete cooperation from all parties in the performance of this review.
l A. J. Kempiaki, P.E. /
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1.0 INTRODUCTION
At the request of the Nuclear Regulatory Commission (NRC), Commonwealth Edison Company (CECO) obtained the services of an outside engineering-construction firm, CF Braun, to conduct an independent review of the seismic, safety related and seismic supported, non safety related heating, ventilating and air conditioning (liVAC) systems installed in Unit I of CECO's La Salle County Station in La Salle County, Illinois.
On August 11, 1982 in a public meeting at th'e NRC region III offices.
Braun presented their qualifications and experience in the design of HVAC systems for nuclear, industrial and commercial installations.
The work plan including, quality control and quality assurance require-ments, was presented to the NRC on August 24, 1982 at the NRC region III offices.
On August 23, 1982 Braun sent the review team project manager, QA engineer, QC supcrvisor, and IIVAC technical advisor to La Salle County Station to formulate the procedures and begin project operations.
This interin report presents the progress and status of this independent (s) liVAC review. It includes the following items.
Scope Work Plan Summary Status Outlook / Projections The attachments provide the following information.
Appendix A - List of documents received from CECO /S&L/Zack Appendix B - QC Procedures Appendix C - QA/QC Qualification Appendix D - Observation / Finding Reports Appendix E - Personnel Experience Summaries (v) t
,yy,, C F CRAUN O CO Page 3 Commonwealti ..dison Co INDEPENDENT HVAC REVIEW Project 6356-N
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2.0 SCOPE OF WORK The scope of work for this project is to perform an independent review of the safety-related, and seismic supported non-safety related HVAC systems at the Commonwealth Edison Company (CECO) La Salle County Nuclear Plant. The S&L design is not in question and will not be reviewed.
The review will include all seven La Salle unit one safety-related HVAC systems listed below.
1 - Control Room HVAC System (System Identification Code VC) 2 - Auxiliary Electric Equipment Room HVAC System (VE) 3 - Diesel-Generator Room Ventilation System (VD) 4 - CSCS Equipment Area Cooling System (VY) 5 - Switch Gear Rooms Ventilation Systems (VX), except for the re-circulation duct in the Auxiliary Building HVAC Equipment Room.
("'N 6 - Portions of the Reactor Building Ventilation System (VR) - The
'N ,) following parts of the reactor building ventilation system are sa fe t y-re lated .
- 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 i
isolation dampers, and the duct penetration of the secondary containment boundary.
7 - Those portions of the Standby Gas Treatment System SGTS (VG) installed by the Zack Co.
The review will also include the supports for all three non-safety related but seismically supported systems listed below:
8 - Primary Containment Ventilation System (VP) 9 - Primary Containment Purge System (VQ) 10 - Reactor Building Ventilating System (VR)
The primary objective of this independent review is to provide verification that the HVAC installation by the Zack Co. is in accord-(,--) ance with the Sargent and Lundy design. This will include, but not be
\~' limited to, a review of -
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SCOPE OF WORK Continued Material installed Field and shop welding on supports and ductwork Operability of associated mechanical equipment Design changes as a result of site nonconformances Field testing by Zack Co. up to, and including, any construction testing performed by Zack Co. or their subcontrecrors.
If required, Braun will identify any additional testing or changes necessary to assure that the HVAC systems fulfill their safety function.
Braun will also review the adequacy and results of these additional tests performed by others.
All observations made during the review will be documented and submitted to a Braun site and internal review team composed of senior technical personnel with broad experience in technical management. These review teams will determine if the observation is accurate and has the potential
, ~s for a safety concern.
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All inspection, review activities, quality assurance and project procedures to be performed by C F Braun & Co during this independent review of the HVAC systems will be conducted in accordance with written project and QA instructions.
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3.0 WORK PLAN This section of the report describes the work plan for Braun's independent review of the HVAC installation.
The HVAC technical advisor will compare the S&L design documents to the Zack Co. shop drawings to verify that Zack has correctly interpreted the design documents. Zack's procedures for procure-ment and processing of HVAC material will be reviewed by the QA and welding / material engineers to evaluate their conformance to appropriate S&L design documents and ANSI standards, this will include verification that the materials installed are of comparable quality.
The welding / material engineer will also review the weld procedure qualifications and welder qualifications associated with the duct-work fabrication practices. Any information or testing generated by CECO or Conam will be used to assist in this evaluation. Zack's fabrication procedures will be compared to SMACNA standards and ANSI 509 requirements, as appropriate, in addition to that required by the design documents, p The HVAC technical advisor will survey all the installed duct systems Q as defined in section 2.0. INTRODUCTION. Based on this survey he will select portions of the system whose failure may jeopardize the operation of safety-related equipment for detailed inspection.
The portions selected will include concealed and insulated duct-work. If discrepancies are found in the selected portions, then additional portions of ductwork will be selected for further inspection. Braun is prepared to inspect 100 percent of the system if deemed necessary.
The leak rate and balancing test for the Control Room HVAC System (VC),CSCS Equipment Area Cooling System (VY) and portions of the Reactor Building Ventilation System (VR) will be reviewed in detail to verify system conformance to the design documents. Spot checks will be made of the Auxiliary Electric Equipment Room HVAC system (VE), Diesel Cencrator Room Ventilation System (VD) and Switch Gear Rooms Ventilation Systems (VX) to ascertain that they have been tested to the same quality as that of the systems reviewed in detail. In addition, the HVAC technical advisor will survey the system operating tests performed by CECO to verify that the 8 results confirm the adequacy of the balancing / leak rate tests.
The Structural Technical Advisor will categorize and review the .
nonconformance reports generated against the HVAC support systems.
Structural descrepancies discovered as a result of inspection n activities will be evaluated to determine whether the existing support satisfies the intent of the design. The Structural Technical Advisor will also review any specification or other contract documents which address the structural integrity of the HVAC systems. '
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WORK PLAN Continued A review of the HVAC refrigerant system, subcontracted by Zack, will also be accomplished. Preliminary information indicates that there have been no nonconformanc.es generated against these systems.
In addition to this step-by-step review of the Zack installation, Braun will review all CECO and Zack NCRs and FCRs generated against the installed system. Each document will be categorized by type for example, weld problem; material certification lacking; location / dimensional /
interference discrepancy; fabrication problem; etc. The frequency of occurrence and importance of each category will be assessed. Twenty percent of those types determined to be critical to safety will be inspected in detail to verify that the specified disposition has been correctly implemented. If discrepancies are found, then the remaining NCRs of this type will be reviewed.
The HVAC technical advisor will randomly select other parts of the system to be inspected for similar types of nonconformances. The inspections will result in a determination of whether or not similar types of nonconformances may have existed on these random sections but were not reported, b
( ,/ During Braun's review of the HVAC support nonconformance reports (NCR) they will evaluate 10 percent of the NCR's to determine if the technical justification is correct. If Braun's review determines safety concerns involving significant as-built design changes, then these changes will be evaluated against the design documents. l QA/QC procedures are described in the Project and QA Instructions l which were transmitted to CECO via BL-5, dated September 10, 1982.
Appendix B, QC Procedures has been included in this interim report for information purposes.
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SUMMARY
i The project has been fully staffed in the field with 5 inspectors, 4
' technical advisors, QA engineer and project manager. The welding and material engineer has been reviewing documents in Alhambra and visiting the site as needed. An internal review committee of 3 specialists has been formed in Alhambra to perform a review of those inspection discrepancies which the site committee feels are potential safety concerns.
! L Project and QA instructions were issued as controlled documents which provide the writtea procedures to accomplish the review.
A member of CECO's operating QA group conducted an audit of Braun j
activities on Friday September 10, 1982. Although the audit report has not been received, the auditor indicated that there were no negative findings.
On Monday September 13, 1982 an inspector from the Nuclear Regulatory Commissions Region III's office visited the C F Brauns site office facilities. He was given an uncontrolled copy of the C F Braun l project and quality assurance procedures. During the visit he reviewed i
O several inspection reports (QC-1) and one observation / finding report (QC-2). He talked to the HVAC advisors and reviewed the field inspection activities.
de have performed a field survey for 5 of the 10 HVAC systems requiring review. This has led to the generation of 134 requests for inspections of selected hangers and ductwork sections. Some of the reasons for selecting the hanger and duct sections chosen are its location relative to other safety equipment, similarity to other hangers or duct sections, relative importance compared to other portions of system and type of equipment installed in system such as damper, silencers, cooling coils, etc.
Weld procedure specifications and welder performance qualification tests have been reviewed by our material and welding specialists. We need to resolve questions on the former item while the latter item appears j acceptable pending a more detailed review.
There are approximately 2400 NCRs written against the Zack installation.
Close to 1800 have been written against supports with the remainder '
covering dampers, fans and other HVAC components. Braun has received and reviewed too small a quantity of these NCR to formulate any opinions or provide for any categorization. We are continuing our review efforts as the reports are received.
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SUM 11ARY Continued Inspection has completed or partially completed, 54 of the 134 requested inspection reports QC-1. This has led to the issuance of 12 observation /
finding reports. The site review team has determined that 8 of these
- discrepancies are technically acceptable and 3 are observations requiring CECO disposition with one being held for further review.
Inspection activities have been hampered by accessibility requirements for security concerns, removal of insulation and fireproofing, erection of
! scaffolding and difficulty of getting close to items needing inspection due to existing cable trays, conduits, piping, equipment etc.
Insulation had to be removed from 72 hangers and fireproofing from 55 hangers at the point of connection to the building structure. Fifty one hangers required the installation of scaffolding to provide the required access. This encompasses the ongoing inspection activities.
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- C e' 5.0 STATUS The Project and QA Instruction have been written, reviewed and approved l for use as a controlled document on this project by the Project Manager and the QA Hanager in Alhambra, California. These instructions define the procedures to be followed by all C F Braun personnel in the per-formance of this review.
The HVAC technical advisor and engineer have reviewed the ductwork drawings and performed field' surveys for 5 of the 10 HVAC systems.
Based on this effort they have generated 134 requests for inspections (RFI) of selected hangers and ductwork sections within these systems.
A list of systems, percent complete and number of RFIs follows.
! PERCENT j SYSTEM COMPLETE RFI Control Room HVAC, VC 60 60(1)
Auxiliary Electric Equipment 80 12 Room HVAC, VE Diesel-Cencrator Room Ventilation, VD 100 11 f CSCS Equipment Area Cooling, VY 80 (2)
Switchgear Room Ventilation, VX 100 51
) TOTAL 134
- (1) Includes VE system since VE & VC are on same support l (2) Included with/VD l
The only work remaining for system VE is that portion of ductwork located in Unit 2 which acts as a backup for the Unit i VE system.
I The welding and material specialist has reviewed 6 welding procedure specifications. Comments have been noted on several of these spec-ifications which require further review and discussions with the' contractor. In addition he has performed a preliminary review of 91 welder performance qualification test record packages. The majority appear to be acceptable but a more detailed review is required.
The structural technical advisor has reviewed the 20 availabic non-conformances and found them acceptable. He has developed inspection criteria for surface mounted anchor plates. Sargent and Lundy Report CQD-003490, Revision 0 Assessment of Stitch Welds in HVAC Dudtwork Construction has been reviewed. The results were found reasonable due to the small loads imposed on individual welds. He has evaluated the initial group of discrepancies noted on the observation / finding reports.
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\.3 La Salle -- ' '., M. < :0 STATUgContinued A status of inspection activities follows:
INSPECTIONS REQUESTS, QC-1 Received from HVAC 134 Inspected Complete 47 Partial (1) 7 54 Backlog (2) 80 (1) Fireproofing needs to be removed at attachment of steel member to wall plate otherwise support has been inspected.
(2) Some of the items causing the inspection backlog are as follows:
1 - Insulation needs removal 2 - Removal of fireproofing i 3 - Scaffolding needs to be set up - some ducts are 40' above l floor level.
,s OBSERVATIONS / FINDINGS, QC-2 l 'I Found acceptable 8 Held for material engineer review 1 Observation 3 Finding _0 TOTAL 12
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6.0 OUTLOOK A management audit of project activities will be accomplished during the week of September 20, 1982 by the Manager of Quality Assurance, Alhambra.
Audits of engineering and inspection activities have been scheduled and will be conducted by the project quality assurance engineer during the three weeks commencing September 20, 1982.
The llVAC technical advisor will complete the 3 systems identified in section 3.0 STATUS as well as the reactor building ventilation-VR, SGTS-VG and the 3 non safety related but seismically supported system.
He needs to correlate the design and construction drawings as well as review NCR/FCR, balance / leakage tests, system operating tests and refrigeration tests.
The material and welding specialist will discuss his comments on the welding procedure specifications with the contractor and complete his review of the welder performance qualifications tests. He will also assist in the evaluation of whether or not the installed material is of comparabic quality to that required by the design documents.
A k_-) The structural technical advisor will continue reviewing the nonconformances and participate in the site committee's review of observation / finding reports.
Inspections will continue for the HVAC system survey requests and other inspection requests as a result of NCR reviews.
Outlook for completion of *.his independent review is mid October.
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67e t2 is C F ERAUN O CO Commonwealth Edison Co INDEPENDENT HVAC REVIEW Project 6356-N INTERIM REPORT N La Salle j
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! r APPENDIX A LIST OF DOCUMENTS RECEIVED FROM ZACK, i
- S&L AND CECO j
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Commonwealth Edison Company, 6356-N, September 15, 1982
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,5/,8, C F CRAUN O CO Commonwealth Edison Co INDEPENDENT liVAC REVIEW Project 6356-N INTERIM REPORT La Salle APPENDIX A LIST OF DOCUMENTS RECEIVED FROM ZACK, S&L, AND CECO 1.0 ZACK The following nonconformance reports were received from Zack on September 9, 1982.
NCR # 460 535 612 632 1845(619) 504 571 614 912 1493 510 603 620 1421 1864 534 611 630 1423 The following nonconformance reports were received from Zack on September 14, 1982.
NCR # 604 616 660 1141 1661 1946 2299 606 631 661 1243 1668 1968 607 633 662 1251 1669 1973 608 656 663 1444 1671 2078 609 657 974 1487 1820 2089 613 658 977 1532 1823 2243 615 659 978 1559 1874 2255 O's
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The following purchase orders for Hilti Kwik bolts were received on September 8, 1982:
P.O. # C2232 dated July 12, 1982 P.O. # C4036 dated November 30, 1979 ,
Misec11ancous welding procedures, procedure qualifications and welder qualifications were received on August 26, 1982.
SARGENT 5 LUNDY The following documents were received from Sargent & Lundy on August 16, 1982:
1 La Salle County Station FSAR, Vols. 5 and 7 1
2 June 3, 1976 meeting notes 3 MSS-16.1 1 4 MSS-16.2-A
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6 MF-270.10.1 a 7 RMC-P-1 l r
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n is Commonwealth Edison Co INDEPENDENT HVAC REVIEW Project 6356-N INTERIM REPORT O La Salle APPENDIX A LIST OF DOCUMENTS RECEIVED FROM ZACK, S6L, AND CECO (CONTINUED) 8 RMC-P-2 9 RMC-P-3
- 10 RMC-P-4 l 11 RMC-P-5 i
12 Testing & balancing procedures 4
I The following documents were received from Sargent & Lundy on August 17, 1982:
4 Air Flow Measuring Station List - Supplement to l Sargent & Lundy Specification J-2590 i
Grille List - Supplement to Sargent & Lundy .
Specification J-2590 s Damper List - Supplement to Sargent & Lundy Specification J-2582 The following documents were received from Sargent & Lundy on l September 7, 1982:
Full sized drawings as listed by S&L letter number 42o0-25.
The following document was received from Sargent & Lundy on August l_
30, 1982:
Sargent & Lundy Report CQD-003490, Revision 0, of August 27, 1982, Assessment of Stitch Welds in HVAC Ductwork Construction.
CECO The following document was received from Commonwealth Edison Co on August 12, 1982:
1 The letter from T C Fahner, Attorney General State of Illinois to i J G Keppler, Regional Administrator, United States Nuclear Regulatory Commission dated August 12, 1982. l The following document was received from Commonwealth Edison Co on August 24, 1982:
I The letter from C W Schroeder, Nuclear Licensing Administrator to T M Novak, Assistant Director, Division of Licensing, U S Nuclear Regulatory Commission dated August 24, 1982.
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Commonwealth Edison Co INDEPENDENT liVAC REVIEW Project 6356-N INTERLM REPORT La Salle APPENDIX A LIST OF DOCUMENTS RECEIVED FROM ZACK, S&L, AND CECO (CONTINUED)
The following document was received from Commonwealth Edison Co on August 20, 1982:
The letter from C Reed, Vice President, Commonwealth Edison Co to 11 R Denton, Director, Of fice of Nuclear Reactor Regulation, U S Nuclear Regulatory Commission dated August 4, 1982.
The following document was received from Commonwealth Edison Co i on September 9, 1982: ,
The letter from T M Novak, Assistant Director for Licensing, Division of Licensing, U S Nuclear Regulatory Commission to C Reed, Vice President - Nuclear Operations, Commonwealth Edison Co dated September 8, 1982.
, The following document was received from Commonwealth Edison Co on August 14, 1982: 1 The letter from B R Shelton, La Salle County Station Project Engineering Manager, Commonwealth Edison to G R Boddeker, C F Braun & Co Power 4 Division dated August 13, 1982.
The following document was received from Commonwealth Edison Co on August 25, 1982:
Four (4) letters addressed to NRC Relative to the LSCS IIVAC Review. The !
letters were sent by: (1) Ms. J. S. Goodie, Asst. Att. Gen. of Ill. !
(August 24, 1982); (2) Ms. S. L. Marello (undated - delivered August 24, j
! 1982): (3) Mr. T. Divine, Govt. Acct. Proj . (August 13, 1982); and (4) -
Mr. A. T. Iloward, August 13, 1982).
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sis 13 1*a C F CRAUN O CO Conunonwealth Edison Co INDEPENDENT llVAC REVIEW Project 6356-N INTERIM REPORT
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APPENDIX B QUALITY CONTROL PROCEDURES 14 pages
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Commonwealth Edison Company, 6356-N, September 15, 1982
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