ML23229A006
| ML23229A006 | |
| Person / Time | |
|---|---|
| Site: | 99902056 |
| Issue date: | 08/18/2023 |
| From: | Nicole Coovert NRC/RGN-II/DCI |
| To: | Hunnewell S Tennessee Valley Authority |
| References | |
| Download: ML23229A006 (1) | |
Text
Mr. Scott W. Hunnewell Vice President, New Nuclear Program Tennessee Valley Authority 1101 Market Street, LP 4A Chattanooga, TN 37402
SUBJECT:
NRC AUDIT OF SUBSURFACE INVESTIGATION ACTIVITIES AT CLINCH RIVER NUCLEAR PROJECT SITE
Dear Mr. Hunnewell:
This letter provides a summary of a U.S. Nuclear Regulatory Commission (NRC) audit of subsurface investigation work performed for the Clinch River Nuclear (CRN) project site from July 11-12, 2023. This audit was conducted in accordance with Inspection Procedure (IP) 45052, Review of Geotechnical and Site Characterization Activities.1 As described in the audit summary (Enclosure 1), NRC staff examined the quality assurance (QA) programs of the applicant, and their contractors, agents, and consultants, as applied to geotechnical activities, to verify if the programs are being implemented in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B.
Based on the results of this audit, the NRC staff determined that QA program requirements were being adequately implemented as required by the applicant and their contractors, agents, or consultants. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Should you have any questions concerning this letter, please contact me at 404-997-4510.
Sincerely, Nicole Coovert, Chief Construction Inspection Branch 1 Division of Construction Oversight Docket No.:
99902056
Enclosure:
NRC Audit Report w/attachment: Supplemental Information 1 Agencywide Documents Access and Management System (ADAMS) Accession Number ML22019A083.
August 18, 2023 Signed by Coovert, Nicole on 08/18/23
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE HQ/NRR HQ/NRR HQ/NRR RII/DCO RII/DCO NAME Z. Xi L. Candelario-Quintana J. Thompson L. Colon Fuentes A. Ponko DATE 08/14/2023 08/15/2023 08/17/2023 08/17/2023 08/17/2023 OFFICE RII/DCO NAME N. Coovert DATE 08/18/2023
Enclosure U.S. NUCLEAR REGULATORY COMMISSION (NRC)
Region II Docket Number:
99902056 Applicant:
Tennessee Valley Authority Facility:
Clinch River Nuclear Project Location:
Clinch River, TN Inspection Dates:
July 11 through July 12, 2023 NRC Auditors:
A. Ponko, Senior Construction Inspector, Region II, Division of Construction Oversight (DCO)
L. Colon Fuentes, Construction Inspector, Region II, DCO NRC Accompanying Personnel:
Z. Xi, Geotechnical Engineer, Office of Nuclear Reactor Regulation (NRR), Division of Engineering and External Hazards (DEX)
J. Thompson, Geologist, NRR, DEX L. Candelario-Quintana, Geotechnical Engineer, NRR, DEX Approved by:
Nicole Coovert, Chief Construction Inspection Branch 1 Division of Construction Oversight
2 Audit Summary Clinch River Nuclear Project (CRN) Subsurface Investigation Activities July 11-12, 2023 INSPECTION PROCEDURE 45052, REVIEW OF GEOTECHNICAL AND SITE CHARACTERIZATION ACTIVITIES Project geotechnical sampling and data collection field activities were being performed by S&ME, Inc. (S&ME) under the direction and supervision of RIZZO International, Inc. (RIZZO).
These activities were being performed under a Project Quality Assurance Plan (PQAP) which was prepared by S&ME for RIZZO. Oversight of S&ME field activities was being performed by Sargent & Lundy, L.L.C. (S&L) on behalf of the Tennessee Valley Authority (TVA).
The staff reviewed the S&ME PQAP, RIZZO Quality, Health, Safety and Environmental (QHSE)
Management System Manual (QHSE Manual), as well as, S&ME project work and data collection plans, and work and field instructions to verify that adequate measures had been established for performing field exploration and data collection activities in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. The staff verified that instructions had been established for marking and labeling, packaging, handling, and storage of items to adequately identify, maintain, and preserve the item, including indication of special environments or the need for special controls. The staff also verified that measures had been established to ensure sample identification is maintained either on the sample or on records traceable to the sample throughout use and that special protective measures (e.g., containers, special moisture content levels, and temperature levels) have been specified to maintain acceptable quality. The staff verified that measures exist to promptly identify and resolve non-conformances and conditions adverse to quality in a timely manner.
The staff observed in process core boring at boreholes U1-B06, located under the control building, and U1-B10 and U1-B12, located under the turbine building, to verify that geotechnical drilling and sampling was being conducted in accordance with approved field instructions and the PQAP. The staff also observed the handling and care of newly completed rock core samples and performed a walk down of the core storage facility to verify that the handling, care, and storage of completed rock core samples was in accordance with approved procedures and the PQAP.
The staff verified that qualification records exist for personnel performing activities affecting quality and reviewed a sample of qualification records to verify that measures were being adequately implemented for the training of personnel to ensure that suitable proficiency is achieved and maintained.
The staff reviewed procedures associated with the control of measuring and test equipment (M&TE) and verified that measures were established to ensure that M&TE used in site characterization activities are of the proper range, type, and accuracy and provide for inspection, calibration, adjustment, and maintenance of M&TE at prescribed intervals, using national standards as a basis for calibration. The staff also reviewed the M&TE log and a
3 sampled M&TE issued for use to determine that controls for calibration were being adequately implemented and to verify that in-use M&TE was working as intended, properly calibrated, and uniquely identifiable.
The staff reviewed the audit report that RIZZO relied upon to qualify S&ME as an approved supplier and the audit reports that TVA relied upon to qualify RIZZO and S&L as approved suppliers. The staff also reviewed four surveillance reports conducted by the S&ME project quality assurance manager and four daily surveillance reports prepared by S&L to verify that surveillances were being conducted to confirm that field activities were being performed in accordance with approved procedures and the PQAP. The staff reviewed the S&L surveillance plan to verify that adequate controls had been established to provide assurance that activities, associated with the geotechnical subsurface investigation of the CRN project site, being performed by RIZZO and their subcontractor, S&ME, conform to the project specific documents, industry standards, and procurement documents. The staff verified that TVA, through S&L, was performing adequate oversight of their contractors, agents, and consultants in accordance with the requirements of 10 CFR Part 50, Appendix B.
The staff reviewed four condition reports (CRs) initiated by S&ME to verify that measures were being adequately implemented in accordance with the PQAP to promptly identify, classify, and resolve deficiencies, nonconformances, and conditions adverse to quality in a timely manner.
The staff also reviewed the project observation log to verify if minor deficiencies not warranting a CR were being addressed in accordance with the PQAP.
The staff also verified that project quality records were being stored in accordance with applicable procedures.
Based on the results of this audit, the staff determined that QA program requirements were being adequately implemented as required by the applicant and their contractors, agents, or consultants.
On July 12, 2023, the NRC staff discussed the results of this audit with Mr. Brian McDermott, Director, Licensing and Planning, and other members of your staff. Proprietary and copyright information was reviewed during the audit period but was not included in the audit report.
OTHER OBSERVATIONS AND DISCUSSIONS WITH APPLICANT The staff observed in process core boring at boreholes U1-B06 located under the control building, and U1-B10 and U1-B12 located under the turbine building. The staff examined the core samples collected from these three borings. The cores were placed in sample boxes for rocks and in jars for soil; and displayed on-site for NRC staffs viewing. The staff was able to see fresh samples of various stratigraphic layers such as Rockdell Formation, Fleanor Formation and Bowen Formation. During the in-process core boring observation at borehole U1-B12, the staff was able to observe drilling soil sample refusal at 15 feet (ft) depth and the transition from soil to rock coring. In addition, the staff observed borehole samples for U1-B02, from depths of 24.1 ft to 445.1 ft located below the reactor building. The staff noted that the samples were continuously collected from the borings in accordance with Regulatory Guide (RG) 1.132, Geologic and Geotechnical Site Characterization Investigations for Nuclear Power Plants and industrial standards.
4 The staff discussed issues related to the siting for the planned reactor and potential challenges associated with the design, geotechnical engineering aspects and the geological features of the Clinch River site, particularly as it relates to excavation methods, the associated early site permit conditions and action items. The staff clarified that the geologic mapping permit condition only requires excavations be made available for inspection by the NRC if geologic features are encountered in the subsurface that are contrary to the conditions reviewed and approved in the early site permit.
4 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Applicant and Contractor Personnel Kevin Casey, TVA, Licensing Lead Buck Collins, TVA, Site Construction Manager Brian McDermott, TVA, Director Licensing and Planning Rolando Benitez, Rizzo, Chief Geologist Zach Kurtik, Rizzo, Director QHSE Dan Boles, S&ME, Lead Geotech Julie Robertson, S&ME, Project Manager Nate Peterson, S&ME, Site Manager Tom Dobras, S&ME, QA Manager Dave Nielson, S&L, Senior Manager Geotechnical LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Type Status Description None LIST OF DOCUMENTS REVIEWED Plans, Procedures, and Instructions S&ME CRN-23-0006-01, Project Quality Assurance Plan, CRN Supplemental Geotechnical Investigation, Revision 1 S&ME CRN-23-0003-00, Subsurface Investigation Work Plan, CRN Supplemental Geotechnical Investigation, Revision 0 S&ME CRN-23-0002-01, Geotechnical Data Collection Plan, CRN Supplemental Geotechnical Investigation, Revision 1 S&ME Work Instruction, WI-CRN-002, Personnel Qualifications and Training, Revision 0 S&ME Work Instruction, WI-CRN-003, Hammer Weighing Procedure, Revision 0 S&ME Field Instruction, FI-CRN-001, Site Manager, Revision 0 S&ME Field Instruction, FI-CRN-002, Rig Geologist / Geotechnical Engineer, Revision 0 S&ME Field Instruction, FI-CRN-003, Using Significant Digits in Geotechnical Data, Revision 0 S&ME Field Instruction, FI-CRN-005, Split-Spoon Sampler Dimensional Verification, Revision 0 S&ME Field Instruction, FI-CRN-007, SPT Energy Testing, Revision 0 S&ME Field Instruction, FI-CRN-009, Geotechnical Drilling and Sampling, Revision 0 S&ME Field Instruction, FI-CRN-013, Handling, Care, and Transport of Rock Core Samples, Revision 0
5 S&ME Field Instruction, FI-CRN-020, Lead Geologist/Lead Geotechnical Engineer, Revision 0 S&ME Field Instruction, FI-CRN-030, Special Care of Rock Core Samples, Revision 0 S&L In-Process Surveillance Plan for Professional and Technical Services, Supplemental Geotechnical Investigation at the Clinch River Nuclear (CRN) Site, S&L Project No. 15100-002, Revision 0, June 14, 2023 TVA-NQA-PLN89-A, Nuclear Quality Assurance Plan (NQAP), (Quality Assurance Program Description), Revision 41 RIZZO Quality, Health, Safety and Environmental (QHSE) Management System Manual, Revision 16 ATS-510 Calibration of Caliper, Revision 6 ATS-1022 Calibration of Temperature & Humidity Recorders, Revision 4 Audits & Surveillance Reports RIZZO Supplier Audit Report, Audit No. : QM-A-239012(B), S&ME, Inc. Louisville, TN, July 10, 2023 TVA Audit/Survey No. 2021U-01, Rizzo International Inc.
TVA Audit Report 2021V-07, Sargent & Lundy, L.L.C.
TVA Audit Report 2021V-07-LSA, Sargent & Lundy, L.L.C.
S&ME Surveillance No. QA-SR-22350835A-23-01, June 11, 2023 S&ME Surveillance No. QA-SR-22350835A-23-02, June 12-13, 2023 S&ME Surveillance No. QA-SR-22350835A-23-03, June 22, 2023 S&ME Surveillance No. QA-SR-22350835A-23-04, June 23, 2023 S&L CRN Geotechnical Field Surveillance Daily Report, June 14, 2023 S&L CRN Geotechnical Field Surveillance Daily Report, July 6, 2023 S&L CRN Geotechnical Field Surveillance Daily Report, July 10, 2023 S&L CRN Geotechnical Field Surveillance Daily Report, July 11, 2023 Condition Reports S&ME CR-23-02 S&ME CR-23-03 S&ME CR-23-04 S&ME CR-23-05 Calibration Records S&ME Purchase Order, PO-CRN-02, ATS Certificate of Calibration 3411779, Asset Number 14363, June 5, 2023 S&ME Purchase Order, PO-CRN-02, ATS Certificate of Calibration 3411806, Asset Number 36731, June 5, 2023 S&ME Purchase Order, PO-CRN-02, ATS Certificate of Calibration 3411780, Asset Number 36732, June 5, 2023 S&ME Purchase Order, PO-CRN-02, ATS Certificate of Calibration 3411786, Asset Number 36751, June 5, 2023 Qualification Records S&ME CRN-23-0011-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Exploration, Revision 0 S&ME CRN-23-0012-01, Personnel Qualification Checklist, CRN Supplemental Geotechnical Exploration, Revision 0 S&ME CRN-23-0020-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical
6 Exploration, Revision 0 S&ME CRN-23-0029-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Exploration, Revision 0 S&ME CRN-23-0033-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Exploration, Revision 0 S&ME CRN-23-0034-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Exploration, Revision 0 S&ME CRN-23-0037-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Exploration, Revision 0 S&ME CRN-23-0095-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Investigation, Revision 0 S&ME CRN-23-0114-00, Personnel Qualification Checklist, CRN Supplemental Geotechnical Investigation, Revision 0 Miscellaneous TVA Purchase Order 7455160, RIZZO International, Inc., Revision 1 TVA Purchase Order 7461776, Sargent & Lundy, L.L.C., Revision 0