IR 05000361/2009007
| ML100630838 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/04/2010 |
| From: | Ryan Lantz NRC/RGN-IV/DRP/RPB-D |
| To: | Ridenoure R Southern California Edison Co |
| Shared Package | |
| ML12151A346 | List: |
| References | |
| G20120332, LTR-12-0215, SECY-2012-0243 IR-09-007 | |
| Download: ML100630838 (33) | |
Text
UNITED STATES NU C LE AR RE G UL AT O RY C O M M I S SI O N rch 4, 2010
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - UNIT 2 STEAM GENERATOR REPLACEMENT PROJECT INSPECTION REPORT 05000361/2009007
Dear Mr. Ridenoure:
On December 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a steam generator replacement inspection at your San Onofre Nuclear Generating Station, Unit 2 facility.
The enclosed inspection report documents the inspection findings, which were discussed on February 2, 2010, with Mr. Wharton and other members of your staff.
The inspections examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents two NRC identified findings of very low safety significance (Green). Both if these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest these noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the San Onofre Nuclear Generating Station facility. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at San Onofre Nuclear Generating Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
Southern California Edison Company -2-In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Ryan E. Lantz, Chief Project Branch D Division of Reactor Projects Docket Nos. 50-361 License Nos. NPF-10 Enclosure:
NRC Inspection Report 05000361/2009007 w/Attachment: Supplemental Information Distribution:
See next page
Southern California Edison Company -3-Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Gary L. Nolff Assistant Director-Resources City of Riverside 3900 Main Street Riverside, CA 92522 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Gary H. Yamamoto, P.E., Chief Division of Drinking Water and Environmental Management 1616 Capitol Avenue, MS 7400 P.O. Box 997377 Sacramento, CA 95899-7377 Michael J. DeMarco San Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21C San Diego, CA 92123-1548 Director, Radiological Health Branch State Department of Health Services P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414 The Mayor of the City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)
Sacramento, CA 95814 Douglas K. Porter, Esq.
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770
Southern California Edison Company -4-Albert R. Hochevar Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 R. St. Onge Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Chief, Technological Hazards Branch FEMA Region IX 1111 Broadway, Suite 1200 Oakland, CA 94607-4052
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Greg.Warnick@nrc.gov)
Resident Inspector (John.Reynoso@nrc.gov)
Branch Chief, DRP/D (Ryan.Lantz@nrc.gov)
Senior Project Engineer, DRP/D (Don.Allen@nrc.gov)
SONGS Administrative Assistant (Heather.Hutchinson@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource ROPreports DRS, ITSB, STA (Dale.Powers@nrc.gov)
OEDO RIV Coordinador (Leigh.Trocine@nrc.gov)
Regional State Liaison Officer (Bill.Maier@nrc.gov)
ACESs (Ray.Kellar@nrc.gov)
NRR/DCI/CSGB (Robert.Taylor@nrc.gov)
File located: R:\_REACTORS\_SONGS\2009\SO 2009007-RP-JPR.doc ML100630838 SUNSI Rev Compl. 7Yes No ADAMS 7Yes No Reviewer Initials RL Publicly Avail 7Yes No Sensitive Yes 7 No Sens. Type Initials RL RI:RPBD SRI: RPBD SPE: RPBD C: RPBD JReynoso GWarnick DAllen RLantz
/RA/ /RA/ /RA/ /RA/
3/3/10 3/4/10 3/3/10 3/4/10 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax-0- Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-361 License: NPF-10 Report: 05000361/2009007 Licensee: Southern California Edison Co. (SCE)
Facility: San Onofre Nuclear Generating Station, Unit 2 Location: 5000 S. Pacific Coast Hwy San Clemente, California Dates: March 1, 2009 through December 31, 2009 Inspectors: J. Adams, Reactor Inspector D. Allen, Senior Reactor Inspector I. Anchondo, Reactor Inspector T. Buchanan, Reactor Inspector J. Braisted, Project Engineer C. Denissen, Reactor Inspector M. Bloodgood, Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector A. Fairbanks, Reactor Inspector R. Hickok, Reactor Technology Instructor J. Johnson, Security Specialist S. Makor, Reactor Inspector T. Nazario, Reactor Inspector C. Osterholtz, Senior Operations Engineer F. Peduzzi, Security Team Leader C. Proctor, General Scientist J. Reynoso, Resident Inspector L. Ricketson, Senior Health Physicist B. Schnetzler, Security Team Leader W. Sifre, Senior Reactor Inspector G. Warnick, Senior Resident Inspector M. Young, Reactor Inspector-1- Enclosure
Approved By: Ryan Lantz, Chief Project Branch D Division of Reactor Projects-2- Enclosure
SUMMARY OF FINDINGS
IR 05000361/2009007; 03/01/2009 - 12/31/2009; San Onofre Nuclear Generating
Station, Unit 2 Steam Generator Replacement Report; Steam Generator Replacement Activities;
Other Activities.
The report covered a 10-month period of inspection by resident and regional inspectors. Two Green findings, both of which were noncited violations of significance, were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XIII, Handling, Storage and Shipping, for the failure of contractor personnel to establish measures to ensure adequate controls for the storage and preservation of material, associated with the admixture and fly ash, to be used in the production of safety-related concrete. Specifically, on December 10, 2009, contractor personnel failed to properly control key materials from being exposed to the elements which could damage or deteriorate the material and adversely impact the properties of safety-related concrete. This finding was entered into the licensees corrective action program as Nuclear Notification NN 200703527.
The finding is greater than minor because use of incorrect material, or material whose properties may have been altered due to improper storage, if left uncorrected, would have the potential to lead to a more significant safety concern. The finding is associated with the design control attribute of the Barrier Integrity Cornerstone and affects the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide release caused by accidents or events. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not represent an actual open pathway in the physical integrity of reactor containment and because the concrete for the containment opening had not yet been batched or placed into the containment structure. The finding has a crosscutting aspect in the area of human performance associated with work practices since the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c)
(Section 4OA5.2).
- Green.
The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instruction, Procedures, and Drawings, for the failure of contractor personnel to follow procedures to ensure proper mixing and batching of safety-related concrete. Specifically, on December 19, 2009, contractor personnel failed to ensure each batch contained the specified proportion of hydration controlling admixture. This finding was entered into the licensees corrective action program as Nuclear Notification NN 200715236.
The finding is greater than minor because the failure to follow procedures for mixing containment concrete, if left uncorrected, would have the potential to lead to a more significant safety concern. The finding is associated with the design control attribute of the Barrier Integrity Cornerstone and affects the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide release caused by accidents or events. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not represent an actual open pathway in the physical integrity of reactor containment and because the batch of the concrete in question met the desired design strength as verified by testing. The finding has a crosscutting aspect in the area of human performance associated with work practices since the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c) (Section 4OA5.2).
Licensee-Identified Violations
None
REPORT DETAILS
Summary of Plant Status
On September 27, 2009, Unit 2 was shutdown for a scheduled refueling outage (U2C16) and steam generator replacement. The unit remained shutdown for refueling outage U2C16 at the end of the inspection period.
OTHER ACTIVITIES
4OA5 Other Activities Steam Generator Replacement Activities
.1 Design and Planning Inspections
a. Inspection Scope
This inspection report documents inspection activities related to the San Onofre Nuclear Generating Station, Unit 2, steam generator replacement project.
These steam generator replacement inspection activities are not part of the normal baseline inspection program, but are performed on an as-needed basis. Therefore, no sample size is specified. The inspectors completed the applicable portion of Inspection Procedure IP 50001, Steam Generator Replacement Inspection, with the exception of the post installation verification and testing inspections. These inspections are planned and will be documented at a later date, as necessary.
Engineering and Technical Support Inspections to review engineering and technical support activities were performed prior to, and during, the steam generator replacement outage by resident and regional inspectors. Inspectors reviewed key design aspects and modifications associated with steam generator replacement.
The inspectors reviewed permanent plant modifications (engineering change packages)and documentation, including safety screens and evaluations, to verify that they were performed in accordance with regulatory requirements and plant procedures. The inspectors also reviewed manufacturer records of parts and tubes of the replacement steam generators and reviewed preservice baseline eddy current examination results of new tubes. These inspections are documented in NRC Inspection Report 05000361; 362/2009003, Sections 1R08 and 1R18, and NRC Inspection Report 05000361; 362/2009004, Section 1R17.
Specific documents reviewed during this inspection are listed in the attachment.
Lifting and Rigging The inspectors reviewed activities associated with applicable engineering design, modification, testing and analysis associated with steam generator lifting and rigging, including:
- steam generator component safe load paths
- crane and rigging equipment
- heavy load haul path The inspectors focused their review on evaluating for any potential impact to the operating unit. Other inspections completed as part of the baseline inspections are documented in NRC Inspection Report 05000361; 362/2009004, Section 1R13.
Specific documents reviewed during this inspection are listed in the attachment.
Radiation Protection Program An inspection to review radiation protection controls was performed during the steam generator replacement outage by regional inspectors. The results of the inspection are documented in NRC Inspection Report 05000361; 362/2009005, Section 2OS1.
Security Considerations and Adverse Impact to Other Unit The inspectors made frequent observations of security practices to verify that the licensee provided appropriate support for affected vital and protected area barriers during outage activities. The inspectors also checked for potential adverse impacts to Unit 3 (the nonoutage unit) caused by outage activities, equipment configurations, etc.
The inspectors reviewed steam generator replacement activities associated with risk management to minimize any adverse impact on the operating unit and common systems. The results of the inspection are documented in NRC Inspection Report 05000361; 362/2009005, Section 1R13.
Specific documents reviewed during this inspection are listed in the attachment.
b. Findings
No findings of significance were identified.
.2 Steam Generator Removal and Replacement Inspections
a. Inspection Scope
The inspectors conducted steam generator removal and replacement inspections by performing selective inspections, consistent with the safety significance and inspection resources of the following areas:
Welding and Nondestructive Examination Activities Inspectors reviewed or observed the following welding and nondestructive examination activities during the steam generator replacement outage:
- qualification certifications for the Non-Destructive Examinations (NDE) examiners
- contractors and Southern California Edison processes to verify they meet ASME code requirements
- cable tray restoration activities, including post maintenance testing
- results of mechanical snubber functional testing and associated nonconformance reports and nuclear notifications for safety related snubbers The inspection results associated with pre-service NDE inspections are documented in NRC Inspection Report 05000361; 362/2009003, Section 1R08.
Containment Opening Restoration Activities The inspectors reviewed licensee activities related to construction activities associated with material, design, fabrication, installation, examination and testing of the containment temporary opening and restoration.
The inspectors completed the following inspection activities:
- observation of restoration activities and review of the modification packages related to equipment hatch supports, containment liner and containment reinforcement bars
- verification of the ASME code versions and sections to ensure compliance and correct application to the code and other industry standards
- review of key containment design aspects found in the updated final safety analysis report to confirm there are no deviations from the safety analysis and licensing basis, including review of 10 CFR 50.59 screenings and evaluations
- review of the liner plate welds strength analysis to verify that the restored liner will be as strong as the original uncut liner
- review of the containment concrete pour analysis to ensure there will be no adverse impact on the liner plate
- review of the design requirements of liner plate stiffeners to ensure the design requirements were adequate to withstand the loads imposed during concrete placement operations
- visual inspections of liner plate stiffeners to confirm proper structural design requirements were implemented
- confirming the use of dedicated new anchor heads during tendon restoration or if reused anchor heads were placed in service that material integrity was verified by inspection
- confirmed that new tendon strands were used and adequate to support containment structural requirements
- review of the tendon duct or sheathing restoration process to ensure the tendon activities were adequate, including grease fill and retensioning, to ensure containment structural integrity was not impacted, including visual inspections of the installed vertical and horizontal replacement tendon sheathing to confirm leak tightness
- review of the engineering evaluations associated with containment opening repairs to re-enforcement bars including CadWeld joint design and weld splices
- confirmed use of weld splices in place of CadWelds satisfied code requirements to ensure it meet all aspects of the original containment structural design
- review of the CadWeld purchasing, installation and testing specifications
- observations of CadWeld sister splices in the field including verification of sister splices were made by each welder for the CadWeld splices (under the same conditions and location) and subsequently tensile-tested to ensure adequate tensile strength of the joint was achieved
- concrete batch plant operations including material storage and handling of concrete components
- material test results (cement, fine and coarse aggregate, water, and admixtures)
- concrete mix and proportion data, including batching results
- concrete transportation and placement Relative to installation of concrete, the inspectors witnessed placement of concrete in the containment wall to restore the temporary construction opening. The inspectors examined the reinforcing steel to ensure it was installed in accordance with design requirements and was properly cleaned, observed the concrete forms to ensure tightness and cleanliness. The inspectors reviewed placement activities to ensure that activities pertaining to concrete delivery time, free fall, flow distance, layer thickness and concrete consolidation conformed to industry standards established by the American Concrete Institute (ACI). Concrete batch tickets were examined to ensure that the specified concrete was being delivered to the site. The inspectors also observed testing of the plastic concrete for slump, temperature, and molding of the concrete cylinders for
testing. Reviews were performed to ensure concrete testing was performed and the cylinders were molded in accordance with applicable American Society Testing and Materials (ASTM) requirements. In addition, the inspectors reviewed activities to ensure that concrete testing was performed by qualified personnel from an independent testing company, and that concrete placement activities were continuously monitored by licensee and contractor quality control and quality assurance personnel.
The inspectors examined the concrete batch plant to verify proper storage and separation of materials and temperature controls. The inspectors reviewed results of quality control acceptance testing performed on materials (cement, fine and coarse aggregate, and admixtures) used for batching. The inspectors also reviewed records documenting inspection of the concrete batch plant and the concrete truck mixers.
Activities were reviewed to determine if the contractors inspection of the trucks and batch plant were performed in accordance with the guidance of the National Ready Mix Concrete Association, if the batch plant scales were calibrated in accordance with National Ready Mix Concrete Association recommendations, and if mixer efficiency tests were performed on the truck mixers in accordance with ASTM C-94. The inspectors reviewed the concrete mix data to ensure that mix proportions for delivered concrete were selected based on trial concrete mix results, that quality control acceptance criteria for the plastic concrete were based on the trial mixes, and that the trial mix met concrete strength requirements.
Lifting, Rigging and Steam Generator Movement and Reconnection Activities The inspectors observed and reviewed activities throughout the refueling outage associated with heavy lifting and rigging. The inspectors observed the implementation and reviewed documentation related to several structural modifications associated with the heavy lifting activities.
The inspectors also observed and reviewed engineering evaluations concerning the removal and reinstallation of the following structural modifications:
- construction of the outside lift system and runway
- lifting and rigging preparations associated with old steam generators removal
- interference removal and replacement of replacement steam generators
- temporary handling equipment construction and removal
- structural supports to facilitate steam generator replacement
- reactor cavity decking construction and removal
- movement and reconnection of replacement steam generators
- steam generator hold down / skirt bolts
- transfer of old steam generators to temporary storage The results of this inspection are documented in NRC Inspection Report 05000361; 362/2009004, Sections 1R13 and 1R18.
Outage Operating Conditions The inspectors used Inspection Procedure 71111.20 to verify proper outage conditions.
Partial completion of this inspection are documented in NRC Inspection Report 05000361; 362/2009005, Section 1R20.
Radiation Protection Controls An inspection to review radiation protection controls was performed during the steam generator replacement outage by regional inspectors. The results of the inspection are documented in NRC Inspection Report 05000361; 362/2009005, Section 2OS1.
Foreign Materials Control The inspectors performed frequent observations of the steam generator replacement activities to verify the licensee was implementing proper foreign materials controls. In particular, the inspectors observed controls related to reactor coolant system and secondary side openings.
Temporary Services The inspectors reviewed the work package and drawings, and then observed the installation, use, and removal of temporary services in the containment building during the outage. Instructions for the use and controls for construction power, acetylene, oxygen, and argon were reviewed, and the actual installation of each system was compared to the approved system sketches.
Additional Post-installation Verification and Testing The inspectors observed implementation of the licensees post-installation inspections and verifications of cable splicing and continually checks. Note that post-installation and testing activities are planned to occur after the conclusion of the inspection period for this report.
Storage of Old Steam Generators The inspectors observed the transport of the old steam generators and reviewed the radiological safety plans for the temporary storage of the old steam generators.
Specific documents reviewed during this inspection are listed in the attachment.
b. Findings
1. Deficiencies Associated with Material Storage of Concrete Batching
Introduction.
The inspectors identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XIII, Handling, Storage and Shipping, for the failure of contractor personnel to establish measures to ensure adequate controls for the storage and preservation of material, specifically the admixture and fly ash, to be used in the production of safety-related concrete.
Description.
On December 10, 2009, the inspectors visited the batch plant and observed the following:
- Fly ash was stored in a locked warehouse; however, several pieces of siding were missing and the structure contained openings in the roof, which allowed water and moisture to enter the building.
- The High-Range Water Reducing admixture, HWRA-PS1466, contained in 55 gallon drums, was not being stored in accordance with manufacturers recommendations, in that; they were being stored outside and not maintained above 40°F. The local area temperature records indicated that temperature dropped below 40°F on December 8, and no additional temperature records were available at the location where material was being stored.
- Contractor personnel surveillances for batch plant activities had been performed on July 10, July 22, and October 23, 2009; however, no other surveillances or receipt inspections for the Boral Micron, fly-ash, and admixtures had been performed or documented between October 23 and December 10, 2009, to ensure that concrete ingredients were controlled, handled, and protected properly.
The inspectors had concerns with these observations and discussed them with the licensees steam generator replacement project personnel. As a result, additional surveillances from December 12-18, 2009, were initiated by the licensees quality assurance personnel in accordance with station procedures. The results of these surveillances confirmed the conditions noted by the inspectors above. During these surveillances, the materials in question were verified, receipt inspected, and stored in accordance with the licensees specification, manufacturers data sheets, and ACI standards.
Specification SO23-617-10, Specification for the Purchase of Containment Opening Concrete, Revision 1, Section 8.1, stated, in part, that, The method of storing of all such materials shall be in accordance with ACI 301 and 304R. In addition, Section 16.3.2.A stated, in part, that, Buyers quality control shall insure that the concrete ingredients are stored, controlled, and protected properly. The American Concrete Institute standard 304R-3 referenced in Specification SO23-617-10, Section 2.3, stated that, All cement should be stored in weather tight, properly ventilated structures, to prevent absorption of moisture. Further, Section 2.4 stated, in part, that Fly ash, ground slag, or other pozzoloans (cement extenders) should be handled, conveyed and stored in the same manner as cement. Finally, the product data sheet for the HWRA-PS 1466, stated that, The admixture must be stored at temperatures above 40°F.
Consequently, the licensee initiated Nuclear Notification NN 200703527 to evaluate the issues to identify and correct any human performance errors that may have contributed to these storage measures not being established and controls for the storage and preservation of material not being properly implemented.
Analysis.
The failure of contractor personnel to establish measures and ensure adequate controls for the storage and preservation of material, specifically the admixtures and fly ash, to be used in production of safety-related concrete was a performance deficiency. The finding is greater than minor because use of incorrect material, or material whose properties may have been altered due to improper storage, if left uncorrected, would have the potential to lead to a more significant safety concern.
The finding is associated with the design control attribute of the Barrier Integrity Cornerstone and affects the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide release caused by accidents or events. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not represent an actual open pathway in the physical integrity of reactor containment and because the concrete for the containment opening had not yet been batched or placed into the containment structure. The finding has a crosscutting aspect in the area of human performance associated with work practices since the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c).
Enforcement.
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XIII, Handling, Storage and Shipping, states, in part, that measures shall be established to control the storage and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
Specification SO23-617-10, Specification for the Purchase of Containment Opening Concrete, Revision 1, established the manufacturer recommendations and American Concrete Institute ACI 304R-3 requirements for the storage and preservation of material, specifically the admixtures and fly ash, to be used in production of safety-related concrete. Contrary to the above, on December 10, 2009, the licensee failed to maintain materials to be used in safety-related concrete in accordance with quality controls specified in Specification SO23-617-10. Specifically, the licensee did not properly control key materials from being exposed to the elements which could damage or deteriorate the material, thus adversely affecting the properties of the concrete.
Because this finding is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notification NN 200703527, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000361/2009007-01, Failure to Adequately Store and Preserve Materials for Used in Safety-Related Concrete.
Deficiencies Associated with Concrete Mixture
Introduction.
The inspectors identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, for the failure of contractor personnel to follow procedures to ensure proper mixing and batching of safety-related concrete.
Description.
On December 19, 2009, the inspectors observed concrete batching operations and delivery to the site associated with Unit 2 containment restoration activities. During the second delivery of concrete (Load 2), the inspectors reviewed the batch ticket at the site and identified incorrect proportions for the hydration controlling admixture (Delvo stabilizer). The batch ticket was signed by contractor quality control personnel prior to leaving the batch plant in accordance with the Specification SO23-617-10, Specification for the Purchase of Containment Opening Concrete, Revision 1.
The batch ticket was also reviewed by field engineering and quality control personnel upon arrival at the site but failed to identify any errors. The inspectors noted a discrepancy with the Load 2 batch ticket in that the quantity of Delvo admixture was incorrect. The inspectors noted the Delvo admixture quantity was approximately 53 percent of the required amount for the Load 2 batch as specified in the approved design mix. The inspectors immediately informed the licensee quality assurance personnel at the site of their concern that the concrete batch did not contain the specified design mix proportions for the Delvo admixture. Contractor engineering personnel informed the inspectors that the batch ticket information was acceptable because it was believed to be a computer error. The inspectors contacted the batch plant, and spoke with the operator to confirm the error, and determined that the Delvo admixture quantity on the batch ticket was, in fact, correct and the admixture quantity in the batch was not proportioned correctly. Because of the prompting by the inspectors, the licensee acknowledged that an error had occurred with the proportioning at the batch plant and documented this condition in Nuclear Notification NN 200715236.
Specification SO23-617-10, Section 12.2.1 stated, in part, that, Concrete shall be proportioned according to the approved design mixture and that materials shall be measured and mixed in accordance with ASTM C 94. In addition, Section 12.2.4 stated that, No truck shall leave the batch plant without carrying a completed batch ticket signed by the batch plant operator and countersigned by licensees or buyers quality control personnel.
After the inspectors identified the issue, subsequent batch tickets were reviewed in detail. In addition, an engineering evaluation was needed to determine whether the concrete in place was acceptable. This evaluation consisted of re-creating a representative concrete mix of the batch in question (Load 2) and concluded that the concrete in place would meet its design strength based on representative test cylinder break results.
Analysis.
The failure to follow procedures, such that the second concrete batch (Load 2)contained incorrect proportions of the Delvo stabilizer admixture, was a performance deficiency. The finding is greater than minor because the failure to follow procedures for mixing containment concrete, if left uncorrected, would have the potential to lead to a more significant safety concern. The finding is associated with the design control attribute of the Barrier Integrity Cornerstone and affects the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide release caused by accidents or events. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not represent an actual open pathway in the physical integrity of reactor containment and because the
batch of the concrete in question met the desired design strength. The finding has a crosscutting aspect in the area of human performance associated with work practices since the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c).
Enforcement.
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Specification SO23-617-10, Specification for the Purchase of Containment Opening Concrete, Revision 1, established the quality controls associated with the mixing of containment concrete and stated, in part, that, Concrete shall be proportioned according to the approved design mixture and that materials shall be measure and mixed in accordance with ASTM C 94.
Contrary to the above, on December 19, 2009, contractor personnel failed to adequately mix and batch concrete in accordance with Specification SO23-617-10, Specification for the Purchase of Containment Opening Concrete. Specifically, contractor personnel failed to correctly proportion the hydration controlling admixture in concrete Load 2, in accordance with the approved design mixture as specified in Specification SO23-617-10, and the load was subsequently placed in the Unit 2 containment opening. An engineering evaluation was required to assess the concrete properties of the incorrect proportion mixture to assure there was no safety impact to the Unit 2 containment. The result of the evaluation determined the Load 2 concrete was minimally impacted but overall strength requirements were satisfactory.
Because this finding is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notification NN 200715236, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000361/2009007-02, Incorrect Mixing and Batching Associated with Concrete.
4OA6 Meetings
Exit Meeting Summary
On December 11, 2009, the inspectors presented results of the inservice team inspection to Mr. Al Hochavar, Station Manager, and other members of the licensee staff. The licensee acknowledged the issues presented.
On February 2, 2010, the inspectors presented the inspection results to Mr. Mike Wharton, Manager, Steam Generator Replacement Project, and other members of the licensees staff. The licensee acknowledged the observations and findings presented.
Some proprietary information was reviewed during this inspection but no proprietary information was included in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Armas, Supervisor, Maintenance Engineering Fluid Process
- D. Axline, Technical Specialist, Nuclear Regulatory Affairs
- D. Bauder, Plant Manager
- J. Carey, Technician, Health Physics
- G. Cook, Manager, Nuclear Regulatory Affairs
- D. Todd, Manager, Site Projects Oversight
- K. Gallion, ALARA Supervisor, Health Physics
- S. Genshaw, Manager, Maintenance Engineering
- C. Harberts, Manager, Steam Generator Replacement Project
- A. Hochevar, Station Manager, Plant Operations
- E. Hubley, Director, Maintenance & Construction Services
- L. Kelly, Engineer, Nuclear Regulatory Affairs
- J. Madigan, Manager, Health Physics
- A. Matheny, System Engineer
- A. Meichler, Mechanical/System Engineering Supervisor
- M. Mihalik, Areva Project Manager, Steam Generator Replacement Project
- R. Nielsen, Supervisor, Nuclear Oversight
- B. Power, Operations Manager, Catalina Pacific
- C. Ryan, Manager, Maintenance & Construction Services
- D. Schafffer, Civil Engineer
- M. Wharton, Manager, Steam Generator Replacement Project
- G. Vechinski, Inservice Inspection/Steam Generator Support Supervisor
NRC Personnel
None
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000361/ NCV Failure to Adequately Store and Preserve Materials for Used in 2009007-01 Safety-Related Concrete (Section 4OA5)
- 05000361/ NCV Incorrect Mixing and Batching Associated with Concrete 2009007-02 (Section 4OA5)