**NRC INSPECTION MANUAL** NMSS/RII

INSPECTION PROCEDURE 88139

VENTILATION AND CONFINEMENT SYSTEMS

PROGRAM APPLICABILITY: 2630

88139‑01 INSPECTION OBJECTIVE

01.01 To determine whether quality assurance (QA) plans, instructions,
and procedures for inspection of ventilation and confinement systems
have been properly established in the facility QA Manual.

01.02 To determine whether the technical requirements, detailed or
referenced in the facility Construction Authorization Request (CAR) and
the Safety Evaluation Report (SER) associated with safety-related
ventilation and confinement systems have been adequately addressed in
the construction specifications, drawings, and work procedures.

01.03 To determine, through direct observation and independent
evaluation of work, whether the installation, of ventilation and
confinement systems, is in compliance with U.S. Nuclear Regulatory
Commission, (NRC) requirements, licensee commitments, and applicable
codes.

01.04 To determine whether: (1) the licensee is adequately implementing
the QA program associated with ventilation and confinement systems,
including preparing, reviewing, and maintaining a system of quality
records; (2) the records reflect work accomplished consistent with NRC
requirements and SER commitments; and (3) the records indicate any
potentially generic problems, management control inadequacies, or other
weaknesses that could have safety significance.

88139‑02 INSPECTION REQUIREMENTS

02.01 [Adequacy and Effectiveness of Construction-Implementing Work
Procedures]{.underline}.

a.  Verify that contractor/subcontractors, with responsibilities for
    installing safety-related ventilation and confinement systems, have
    approved procedures describing the administrative controls and work
    processes to be implemented, to ensure construction activities have
    been accomplished according to design requirements.

b.  Verify that procedures prescribe adequate methods, of quality
    control (QC) inspection, to ensure that the as-built condition of
    safety-related ventilation and confinement systems meets specified
    engineering requirements and drawings. As part of the assessment of
    the QC inspection procedures (IPs), ensure the procedures include or
    reference appropriate quantitative or qualitative acceptance
    criteria for determining that the prescribed activities have been
    accomplished satisfactorily.

c.  Verify that contractors have established procedures for ensuring
    that craft and inspection personnel performing construction work on
    safety-related ventilation and confinement systems are qualified to
    perform their assigned work.

02.02 [Adequacy and Effectiveness of Construction Work and Work
Activities]{.underline}. By direct observation, interviews, and
independent evaluation of work performance, work-in- progress, and
completed work, determine whether activities regarding ventilation and
confinement systems are being accomplished in accordance with NRC
requirements, CAR and SER commitments, the QA Plan, and licensee
procedures and specifications.

a.  [Installation Activities]{.underline}.

    1.  Witness portions of the installation activities of
        safety-related ventilation and confinement systems, to verify
        the following:

        a.  The latest issue (revision) of applicable drawings or
            procedures is available to the installers and is being used.

        b.  Modifications to supports are approved by appropriate
            personnel before implementation.

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2.  Witness portions of the installation and testing (if required) of
    concrete anchor bolts, to verify that anchor-bolt type, diameter,
    embedment length, shoulder‑to‑cone measurement, and torque
    requirements (where applicable), meet installation requirements.

3.  Determine whether required inspection activities are in process and
    observe for adequacy. In particular, determine whether QC inspection
    of welder qualification procedures and welding of supports is
    conducted.

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b.  [Major Construction Activities]{.underline}.

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1.  [Receipt]{.underline}.

> Review receipt-inspection reports for major components of ventilation
> and confinement systems and verify receipt-inspection requirements
> have been implemented.

2.  [Storage]{.underline}.

> Review receipt reports for one High Efficiency Particulate Apparatus
> (HEPA) filter system procurement and at least two other types of
> Heating Ventilation and Air Conditioning (HVAC) system material (e.g.,
> scrubbers, fans, dampers, weld filler metal, fasteners, expansion
> anchors). For each report, independently verify conformance with
> storage administrative controls and technical requirements.

3.  [Fit-up and Alignment]{.underline}.

> Select two recently completed or in-progress bolted connections and
> verify the following:

a.  The bolted connections conform to procedure- or drawing-established
    tolerances for mutual parallelism and axial alignment.

b.  Layout instruments are calibrated. Equipment and instruments used
    for in-process monitoring and inspection should be calibrated to
    standards traceable to industry-recognized criteria. Calibration and
    control measures are not applicable for rulers, tape measures,
    levels, and other such coarse-measurement devices that provide
    accuracy, as received from the manufacturer.

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4.  [Edge Finish]{.underline}.

> Select two flanges and two supports that are ready for welding and
> verify that the flange faces and edges conform to
> procedure/specification requirements.

5.  [Anchor Bolts, Embedded Weldments, and Plate Anchors]{.underline}.

> Select three anchor-bolt installations and verify the installations
> conform to established procedure requirements.

6.  [Bolted Connections]{.underline}.

> Select two bolted connections and verify that the installations and
> inspection activities conform to established requirements. Verify that
> torque wrenches used for these bolted connections had been calibrated
> as required by the construction specification.

7.  [Welded Connections]{.underline}.

> Select four welded connections in an HVAC system and verify they
> conform to established requirements for weld identification, use of
> appropriate welding procedure(s), and control of welding materials,
> etc.

c.  [As‑Installed Equipment]{.underline}.

> Observe the completed installation of the following equipment for
> proper location, configuration, identification, and damage. The basis
> for this determination shall be the CAR/SER system description, piping
> and instrumentation diagrams (P&IDs), specifications, and installation
> drawings. Select a minimum of five items from the list below.

1.  Seismic support for ductwork (required);

2.  Ductwork (required);

3.  Isolation dampers;

4.  Recirculation test loops around fans and isolation dampers;

5.  Radiation, smoke, and toxic chemical monitor;

6.  Pressure-drop instrumentation across filter banks;

7.  Instrumentation for the detection of excess ambient temperature;

8.  Fresh air intake elevation from grade level;

9.  Fans and motors;

10. Air handling units;

11. Exhaust vents; and

12. Filters.

02.03 [Adequacy and Effectiveness of the Training and Qualification of
Personnel]{.underline}. Verify that craft, testing, and QC personnel
involved in performing confinement and ventilation-system construction
and inspection activities are qualified to perform their job functions.

02.04 [Adequacy and Effectiveness of the System of Records]{.underline}.
Verify that records for installing and testing safety-related
ventilation and confinement systems are as specified, reviewed by the
contractor for accuracy and assurance; and the recorded information
meets project requirements, has been approved, and stored and maintained
sufficient to support technical and contractual requirements.

a.  Review licensee/contractor documentation requirements covering work
    performed for ventilation and confinement systems. Determine the
    effectiveness of the document review systems by comparing records
    against requirements for accuracy and completeness.

b.  Review nonconformance reports for items of the ventilation and
    confinement systems.

c.  Review relevant portions of licensee and contractor audit reports
    concerning the installation of ventilation and confinement systems.

88139‑03 INSPECTION GUIDANCE

For each of the inspection elements, the inspectors should: (1) obtain a
copy of the contractor=s procedures and the related industry codes and
standards to which the contractor has committed; (2) become familiar
with the contents of the procedures and standards; and (3) assess
whether the procedures and their implementation adequately conform to
the applicable commitments.

Suggested sample selections are included in the section below. Follow
the suggestions or choose samples more appropriate for the inspection,
based on construction progress, completion of contractor=s QA/QC
reviews, or inspectors experience. Use judgment in determining sample
selection, focusing on examining the most important aspects of the
particular activity being inspected. The intent is to establish a high
level of assurance the end product meets requirements.

03.01 [General Guidance]{.underline}.

a.  Description of the ventilation and confinement systems is contained
    in the facility=s CAR and the SER. The inspectors should then use
    the CAR and SER sections during the review of the licensee=s
    implementing construction specifications, drawings, work procedures,
    and QA implementing procedures. The inspectors also should review
    the documents listed in the reference section of this procedure for
    in‑depth technical details needed for the inspection.

b.  Because installation work on the ventilation and confinement systems
    is normally carried out over an extended period of time, a series of
    inspections may be needed to fully complete this procedure.
    Additionally, some licensee contracting arrangements may be such
    that several different contractors will be involved in the
    installation work. If this is the case, selected parts of this
    procedure may have to be repeated to adequately cover the total
    effort. Regional evaluations and appropriate adjustments to this
    procedure may be necessary to ensure inspection continuity during
    the extended period of time involved and to accommodate the various
    contracting arrangements encountered.

c.  Findings from this inspection activity should address each element
    as being satisfactory, unresolved, and requiring resolution, or in
    violation and requiring correction. When significant inadequacies
    are identified in specifications or procedures indicating weaknesses
    within the preparing technical organization, the inspectors should
    so inform cognizant regional supervision. The issue should be
    addressed at the appropriate level of licensee management.

d.  Particular attention should be given to the traceability of material
    and equipment, to prevent the use of incorrect or defective
    materials, parts and components. The inspectors should review the
    licensee=s/contractors implementing procedures that correspond with
    American Society of Mechanical Engineers (ASME) NQA-1-1994, Basic
    Requirement 8, AIdentification and Control of Items,@ and applicable
    codes and specifications. The inspectors should verify that the
    licensee has established measures for identification and control of
    materials, parts, and components, and for traceability to the
    approved design basis and to the source. The inspectors should
    assure that required identification of the item is maintained by
    heat number, part number, serial number, or other appropriate means,
    either on the item or on records traceable to the item, as required,
    and that required markings are on the item.

e.  The inspectors should note markings on material and equipment and
    verify that the markings represent material and equipment as
    specified by the design drawings and specifications. In the case of
    fasteners, compliance with the applicable material specification
    (e.g., American Society for Testing and Materials or ASME material
    and grade) should be verified by required markings on bolts and nuts
    and certified material test reports or certificates of conformance,
    as required by the applicable procurement drawings and
    specifications, and/or by the applicable codes and specifications.
    In the case of vendor‑supplied equipment assemblies containing
    fasteners, samples should be inspected to verify compliance with
    approved vendor drawings and specifications and other information
    such as materials used for equipment-qualification tests and/or
    analyses. Caution should be exercised to ensure that the required
    markings on material and equipment, including fasteners, not only
    exist, but that the markings indicate the correct material and grade
    as specified.

3.02 [Specific Guidance]{.underline}.

a.  [Adequacy and Effectiveness of Construction-Implementing Work
    Procedures]{.underline}. The inspectors should review the
    implementing and QC IPs for ventilation and confinement
    construction. Verify the procedures have been approved and specify
    the work processes, adequate QC inspections and methods, and
    management controls for the major construction activities. Ensure
    the major construction activities are completed according to drawing
    and procedure requirements and include or reference appropriate
    quantitative or qualitative acceptance criteria.

b.  [Receiving]{.underline}. The inspectors should select a sample of
    procurement documents regarding: (specifications and drawings,
    various components such as HEPA filters, prefilters, and spark
    arrestors). Verify that these documents specify the shape, size,
    dimension, and material type and grade, and the Certificate of
    Conformance certifies the components meets the construction,
    material, test, and qualification requirements.

c.  [Storage]{.underline}. The inspectors should ensure storage and
    warehousing procedures for ventilation and confinement system
    components, and/or the procurement documents reviewed require the
    following:

    1.  Access is controlled to the storage area to maintain the quality
        of the materials received.

    2.  An adequate marking system is used to maintain the identity of
        material in storage.

    3.  Material is protected from the environment and weather, as
        appropriate. Structural steel for supports is protected from
        corrosion.

    4.  Nonconforming material is segregated.

    5.  Motors, dampers, and heaters are checked to ensure wrappings are
        not disturbed and items are not removed from storage without
        proper authority.

    6.  HEPA filters and adsorbers are stored in their original cartons
        in an environmentally controlled room.

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d.  [Fit-up and Alignment]{.underline}. The inspectors should ensure
    construction procedures or drawings for ventilation and confinement
    system require flange faces to conform to established tolerances for
    mutual parallelism and axial alignment.

e.  [Edge Finish]{.underline}. The inspectors should ensure construction
    procedures for ventilation and confinement system provide criteria
    for the following:

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1.  Flange-face surface finish.

2.  Surface finish of weld preparations.

    f.  [Anchor Bolts, Embedded Weldments, and Plate
        Anchors]{.underline}. The inspectors should assess whether the
        contractor=s construction procedures for ventilation and
        confinement systems adequately address the following:

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1.  The minimum edge distance for bolts, studs, or bars with shear
    loading.

2.  Expansion-anchor testing.

    g.  [Bolted Connections]{.underline}. The inspectors should ensure
        construction procedures for ventilation and confinement systems
        require the following:

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1.  Maximum and minimum-edge distance for slotted, oversized, and
    standard bolt holes for bolted steel-duct support structures.

2.  Maximum and minimum hole size for standard, oversized,
    short-slotted, and long-slotted holes for bolted connections for
    bolted steel-duct support structures.

3.  Minimum spacing requirements for bolt holes for bolted steel-duct
    support structures.

4.  Installation of locking devices for fasteners and threaded joints
    (except for high-strength bolts); engagement of the threads of all
    bolts or studs for the full length of the thread in the nut (unless
    approved by the engineer); and conformance of bolting material to
    drawing requirements.

5.  Calibration of torque wrenches.

6.  Use of beveled washers to compensate for situations where the
    surface of the bolted part in contact with the bolt head has a slope
    greater than 1:20 with respect to the plane normal to the bolt axis.

    h.  [Welded Connections]{.underline}. The inspectors should review
        the construction procedures for welding material greater than,
        or equal to 0.125-inches thick. In addition, assess whether the
        contractor=s procedures adequately address the following:

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1.  Identification of welders and weld operators who are welding on
    steel-duct support structures;

2.  Weld procedure and welder qualification; and

3.  Control of welding material.

    i.  [Material Physical Dimensions and Tolerances]{.underline}. The
        inspectors should ensure construction procedures or drawings for
        ventilation and confinement systems require acceptable
        dimensioning and tolerances for the following:

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1.  Length, elevation, material thickness, joint and seam joining, and
    span for ducting and supports.

2.  Requirements that the taper of duct transitions be at least five
    units in length for each one unit in diameter change.

    j.  [Nondestructive Examination]{.underline}. The inspectors should
        review the construction procedures for ventilation and
        confinement systems, in accordance with the applicable IP. In
        addition, assess whether the contractor=s procedures adequately
        address the following:

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1.  Visual inspection of production welds according to the visual
    inspection criteria of American Welding Society (AWS) D1.1 or D1.3,
    as applicable.

2.  Requirements for visual-inspection proximity of view, qualification
    of visual-inspection personnel, and the contents of
    visual-inspection reports.

3.  Inspection sampling for full-penetration and partial-penetration
    welds on structural steel-duct or equipment supports.

03.03 [Adequacy and Effectiveness of Construction Work and Work
Activities]{.underline}. Before performing work observation inspections
in the field, review the applicable procedures and industry standards to
ensure familiarity with the requirements and acceptance criteria
pertinent to the planned observations. During field observations, the
inspectors should carry a copy of the appropriate sections of the
contractor=s procedures and industry standards, pertinent to the planned
observations, and verify work is being accomplished using procedures of
the proper revision.

Examples of the major construction activities for important-to-safety
HVAC systems are listed in Section 02.02. Verify the construction work
implemented in the field conforms to the contractor=s construction and
IPs.

In addition to accomplishing the inspections identified in Section
02.02, inspect a substantial sample of one important-to-safety HVAC
system that has some completed activities and other activities in
progress. Verify ducts, housings, fans, dampers, anchors, and services
(i.e., electrical power, drains, etc.) are installed according to
applicable layout drawings and procedures.

During the field observations, the inspectors should interview and
obtain the names of a sample of the craft and QC personnel performing
the observed activities, to assess whether their knowledge of the job
and procedures is satisfactory. The sample size will be determined by
the number of contractor personal performing the activity. Information
on these same personnel will be used pursuant to Section 03.04, below,
to determine the adequacy of their experience, training, and
qualification, including documentation.

03.04 [Adequacy and Effectiveness of the Training and Qualification of
Personnel]{.underline}. The inspectors should interview craft and QA/QC
personnel involved in activities related to the safety-related
ventilation and confinement systems and verify the personnel are
sufficiently knowledgeable of procedure requirements. The inspectors
should also review the training and qualification records for those
individuals to determine if they meet the requirements.

03.05 [Adequacy and Effectiveness of the System of Records]{.underline}.
The inspectors should select a sample of records generated during the
conduct of HVAC system receiving, storage, fit-up and alignment,
bolting, welding, and testing activities and records of qualification
for those craft and QA/QC personnel selected during the performance of
Section 02.02, above. Verify the records selected for examination were
approved by proper authority and were stored and maintained in such a
manner as to demonstrate conformance with procedural requirements.

88139‑04 RESOURCE ESTIMATES

This IP is expected to take, on the average, 32 to 64 hours of
inspection time. It is recognized that the construction-installation
work associated with this procedure may be carried out over an extended
period of time, which may require a series of inspections to fully
complete this procedure. Additionally, some licensee contracting
arrangements may be such that several different contractors will be
involved in the installation work. If this is the case, selected parts
of this procedure may have to be repeated, to adequately cover the total
effort.

88139‑05 REFERENCES

Code of Federal Regulations 10 CFR Part 50, Appendix B, AQuality
Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing
Plants.@

American Society of Mechanical Engineers, (ASME), ASME AG-1, ACode on
Nuclear Air and Gas Treatment,@ (1991).

American Society of Mechanical Engineers, ASME B31.3, AProcess Piping,@
(1998).

American National Standards Institute, American Society of Mechanical
Engineers, ANSI/ASME N509, ANuclear Power Plant Air Cleaning Units and
Components,@ (1980).

American National Standards Institute, American Society of Mechanical
Engineers, ANSI/ASME N510, ATesting of Nuclear Air-Cleaning Systems,@
(1980).

American Welding Society, AWS D1.1, AStructural Welding Code,@ (1998).

American Welding Society, AWS D1.3, AStructural Welding Code - Sheet
Steel,@ (1998).

American Welding Society, AWS D9.1, ASheet Metal Welding Code,@ (1998).

American National Standards Institute, ANSI N690, ASpecification for the
Design, Fabrication, and Erection of Safety-Related Steel Structures for
Nuclear Facilities,@ (1994).

American National Standards Institute, ANSI/ANS 8.1, ANuclear
Criticality Safety in Operations with Fissionable Materials Outside
Reactors,@ (1988).

American Society for Heating Refrigeration and Air Conditioning
Engineers (ASHRAE), ADesign Guide for Department of Energy Nuclear
Facilities,@ (1988).

Duke, Cogema, Stone and Webster, AMixed-Oxide Fuel Fabrication Facility,
MOX Project Quality Assurance Plan (MPQAP),@ Docket Number 070-03098,
under U.S. Department of Energy Contract DE-AC02-99-CH10888, latest
revision accepted by NRC.

Duke, Cogema, Stone and Webster, AMixed-Oxide Fuel Fabrication Facility
Construction Authorization Request (CAR),@ latest revision accepted by
NRC.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.100, Rev. 2,
ASeismic Qualification of Electric and Mechanical Equipment for Nuclear
Power Plants,@ (1988).

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.12, AGeneral
Design Guide for Ventilation Systems of Plutonium Processing and Fuel
Fabrication Plants,@ (1973).

END

ATTACHMENT 1

Revision History for IP 88139

+--------+--------+------------------------+-----+-------+-------------+
| Comm   | Issue  | Description of Change  | Tr  | Tra   | Comment     |
| itment | Date   |                        | ain | ining | Resolution  |
| Tr     |        |                        | ing | Compl | Accession   |
| acking |        |                        | Nee | etion | Number      |
| Number |        |                        | ded | Date  |             |
+--------+--------+------------------------+-----+-------+-------------+
| N/A    | 08     | IP 88139 is a newly    | N   | N/A   | ML071980489 |
|        | /08/07 | issued procedure.      | one |       |             |
|        |        | Issued for MOX         |     |       |             |
|        | CN     | inspection program to  |     |       |             |
|        | 07-024 | improve effectiveness  |     |       |             |
|        |        | and efficiency by      |     |       |             |
|        |        | incorporating and      |     |       |             |
|        |        | consolidating          |     |       |             |
|        |        | ventilation and        |     |       |             |
|        |        | confinement system     |     |       |             |
|        |        | inspection             |     |       |             |
|        |        | requirements.          |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+