ML19320D114
| ML19320D114 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/23/1980 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19320D113 | List: |
| References | |
| NUDOCS 8007180585 | |
| Download: ML19320D114 (6) | |
Text
~
, e i i r
i L
I f L L l' '
l P O Box 5000 e CLEVELAND. oHlo 44101 e TELEPHONE (216) 622-9800 m ILLUMINATING BLDG e 55 PUBLIC SoVARE Dalwyn R. Davidson VICE PRESIDENT SYSTEM ENGINEERING AND CONSTRUL fiON June 23, 1980 Mr. Gaston Fiore111 Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Pe rr'J Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to I. E. Report
Dear Mr. Flore111:
This letter is to acknowledge receipt of your Inspection Report Number 50-440/
80-07, 50-441/80-07, attached to your letter dated May 21, 1980, which I re-ceived on May 23, 1980.
This report identifies areas examined by Messrs.
R. B. Landsman and E. J. Gallagher during the inspection conducted May 5 through 7, 1980.
Attached to this letter is our response to the three (3) items of apparent non-compliance described in Appendix A, Notice of Violation.
This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice",
Part 2, Title 10, Code of Federal Regulations.
Should there be any questions, please don't hesitate to call.
Very truly yours, f-17/
'4m D. R. Davidson Vice President System Engineering and Construction ksz Attachment JUN27gggy 8087180 G 6 6
RESPONSE TO ENFORCEMENT ITEMS Listed below are our responses to Appendix A, Notice of Violation, of United States Nuclear Regulatory Commission I. E. Report 50-440/80-07; 50-441/80-07.
I.
A.
Infraction 10CFR50, Appendix B, Criterion VI (Document Control), states in part that " Measures shall be established to control the issuance of documents such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality."
CEI Corporate Nuclear Quality Assurance Program 0600 requires that re-visions and changes to the technical requirements of specifications be documented, approved and included in the appropriate revision document prior to implementation.
Contrary to the above, issuance of technical instructions and procedures used to perform safety-related soils placement and compaction were not controlled in a manner suitable to assure that activities were performed in accordance with documented procedures. The resident Geotechnical Engineer issued four inter-of fice memos revising
'*e technical requirements of Specification SP-225-4549-00 for excavation and backfill work without formally revising the subject specification.
The inter-office memos revised the lif t thickness for compacting soils, approved equipment for compaction, and directed an alternate method be used to establish a laboratory standard for compacting Class A material.
Inter-office memos are not controlled or distributed to appropriate individuals nor afforded quality assurance review.
B.
Response
1.
Engineering Change Notices stating the provisions in the referenced memoranda are being issued to U. S. Testing (SP-1), National En-gineering (SP-20), S & M Constructors (SP-29), L. K. Comstock (SP-33), and Great Lakes Construction (SP-93). Quality Assurance review will be obtained and controlled distribution will be made to assure receipt by appropriate individuals.
2.
Documentation of decisions made by the Resident Geotechnical Engineer pertaining to backfill work or testing which would change specified requirements will be by means of an Engineering Change Notice or Field Variance Authorization, as appropriate. This policy was documented on June 6, 1980, by the GAI Assistant Project Manager.
3.
Full compliance will be achieved by June 27, 1980.
4 e
+
RESPONSE TO ENFORCEMENT ITEMS
- 1. E. REPORT 50-440/80-07; 50-441/80-07 PAGE 2 II.
A.
Infraction 10CFR50, Appendix B, Criterion XVII (Quality Assurance Records), states in part that "... sufficient records shall be maintained to furnish evidence of activities af fecting quality."
CEI Corporate Nuclear Quality Assurance Program 1700 requires inspection records contain sufficient documentation to provide evidence of the work being performed in accordance with quality requirements.
Contrary to the above, Great Lakes Company quality assurance records for the inspection of safety-related soils work activities did not document the actual lift thickness of material placed nor the actual number of passes by compaction equipment. The acceptance criteria were noted on the inspection record in lieu of actual observations.
In addition, the quality control inspection report was prepared and signed by a Quality Control Inspector other than the one who observed the work activity in progress.
B,
Response
1.
Great Lakes Construction Company (SP-93) quality assurance records for inspection of safety-related soils work activities do document that specified requirements of SP-225 have been met.
Through observation, the GLC Quality Control backfill inspector assured that the specification requirements for each lift were satisfied.
In reporting the specification requirements (acceptance criteria) for each lift, the QC inspector was documenting that the specified minimum number of passes per lif t had been made and that the specified loose lif t height for that placement had not been ex-ceeded.
2.
Great Lakes Construction Company Procedure T/QCP-8 has been revised and includes a revision to Form Number QC-47, entitled " Area Back-fill Record", which is used by the GLC Quality Control inspector to record the type of equipment used, the number of passes, and the lift heights. This revision requires documentation of both the specified requirements and the actual number of passes and loose lift height observed by the QC inspector for each type of compaction equipment used.
Af ter acceptance of T/QCP-8, Rev. 6, an indoctrination and training session was held on June 6, 1980, for the QC inspectors.
3.
Full compliance has been achieved.
L
RESPONSE TO ENFORCDIENT ITEMS
- 1. E. REPORT 50-440/80-07; 50-441/80-07 PAGE 3 Response (Cont'd.)
the 4.
Regarding the unresolved item associated with this infraction, revised forms now require the QC inspector making observations in the field to initial each line or sign the page. A GLC Level II Soils will then review, sign, and date the completed form. This was also covered in the indoctrination and training session held on June 6,1980.
III. A.
Infraction 10CFR50, Appendix B, Criterion V (Instructions, Procedures, and Draw-ings), states in part that "... activities affecting quality shall be prescribed by documented instructions, procedures, and drawings...and shall be accomplished in accordance with these instructions."
CEI Corporate Nuclear Quality Assurance Program 0500 requires activities af fecting quality to be described and accomplished in accordance with instructions and procedures. Appropriate acceptance criteria shall also be provided for determining satisfactory accomplishment of activities.
Contrary to the above, the following provisions were not prescribed and/or accomplished according to documented instructions or procedures:
U. S. Testing Procedure QCP-10, Section 1.2, requires that soil a.
samples be taken from their stockpile and/or source, and be tested in accordance with applicable tests in Section 2.0 (i.e., relative density test). Tests are being performed on samples taken from the field af ter the material has been compacted instead of prior to placement, b.
Perry PSAR, Appendix 2A, Section 10.2, requires " continuous moisture control during fill construction." Provisions do not exist for moisture control of safety-related Class A fill even though water must be added in the field in order to achieve proper compaction.
In addition, no acceptance criteria have been established for moisture control of Class A fill, although moisture contents are required to be taken by the specification, Specification SP-225, Section 1.06.7, states that when fill c.
placement is less than 50 cubic yards per lif t, density tests will be performed once every third lif t.
This is not in appropriate quantitative acceptance criteria for determining that safety-related backfill is being properly placed and compacted in each lift.
u
RESPONSE TO ENFORCDwNT ITEMS
- 1. E. REPORT 50-440/80-07; 50-441/80-07 PAGE 4 B.
Response
Our response is separated into three sections to permit address of each example identified above.
Item A 1.
An analysis of the effects of compaction equipment on the gradation of Class "A" material was performed.
From May 14, 1980, to June 10, 1980, samples were obtained adjacent to each in-place density and daily from incoming truck loads of Class "A" material.
- test, Steve analysis was performed on each sample. The results of the sieve analysis of samples obtained from both incoming shipments and in-process tests were then compared.
Correlation of test results revealed that 98% of the tests demon-strated maximum deviation of i 2% on any sieve.
Ali material analyzed was found to meet specification requirements.
Additionally, the 2% deviation in a sample could be attributed to variations inherent in Class "A" material.
United States Testing Company's Procedure QCP-10, entitled " Quality 2.
Control Procedure for the Inspection of Soil Fill" is being revised to permit sampling from source, stockpile, or compacted fill.
3.
Full compliance will be achieved by July 1, 1980.
Item B 1.
Class "A" fill is compacted to a relative density and not to a percent compaction based on a proctor test. Results of the re_s-tive density tests are independent of the moisture content in a granular material because dry density can be achieved at various moistures. The moisture content of the Class "A" fill is deter-mined per Item 1:06.7 in SP-225, Rev. 3, and is only needed to determine a dry unit weight. A specified range of moisture con-trol is therefore not required.
Additionally, because the Class "A" fill is designed to act as a permeable backfill allowing drairage into the plant's underdrain system, maintaining a specific moisture content would be imprac-tical due to the required permeability of the material.
2.
The PNPP PSAR, Appendix 2I, Section 10.2 states: "The moisture testing frequency should be sufficient to enable continuous moisture control during fill construction." A PSAR Deviation is being issued to clarify that,his statement is applicable only to Class "B" soils.
3 Full compliance will be achieved by July 15, 1980.
L J
RESPONSE 'IO ENFORCEMENT ITEMS 2
I.E. REPORT 50-4h0/80-07;50-441/80-07 PAGE 5 Item C
~
l and 2.
GAI Specification SP-225, Section 1:06.7 states:
"In localized areas of Class "A" Fill placement where less than 50 cubic yards constitutes a single lift, density tests will te performed once every third lift or every 50 cubic yards, whichever is more often. Lifts which are not tested for density shall be placed by methods approved by the RESI-DENT GEOTECHNICAL ENGINEER."
The above statement dictates that: (1) In areas where each lift is less than 25 cubic yards, one density test will be taken at least every third lift.
(2) In areas where each lift is between 25 and 49 cubic yards, one density test will be taken at least every second lift.
(3) In arer where each lift is 50 cubic yards or greater, a density test will be taken in each lift.
Therefore, based on the above, the frequency of in-place density testing in localized (confined) areas is about three times greater than that performed on the same quantity of Class "A" Fi31 placed in the larger open areas. Also, should the frequency of testing as described above call for one den-sity test every third lift, the area tested is always the upper half of the second or middle lift and the lower half of the third or upper lift. It is reasonable to assume that the three lifts have been placed in a similar manner; consequently, the first or lower lift would most likely reach a greater density than the two lifts compacted above it.
The one density test taken would therefore conservatively represent the measurement of average compaction over the total height of three lifts of fill.
Also, as mentioned in SP-225, the lifts in localized areas are placed by methods approved by the RGE. The placing of these lifts receives good inspection coverage by the RGE and Contractor Quality Control.
3 Therefore, bat;ed on the above, we are in full compliance with NRC requirements.
1 1
l l
1
.