ML19320B035
| ML19320B035 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/19/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19320B034 | List: |
| References | |
| 50-440-80-07, 50-440-80-7, 50-441-80-07, 50-441-80-7, NUDOCS 8007090156 | |
| Download: ML19320B035 (2) | |
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Appendix A NOTICE OF VIOLATION-The Cleveland Electric Illuminating Docket No~. 50-440 Company Docket No. 50-441 Based on the results of an inspection conducted on May 5-7, 1980 it appears that certain of your activities were in noncompliance with NRC requirements.
These items are considered infractions.
1.
10 CFR 50, 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 revisions and chsnges to the technical requirements of specifica-tions be documented, approved and included in the appropriate re-vision document prior to implementation.
Contrary to the above, issuance of technical instructions and pro-cedures used to perform safety related soils placement and compac-tion were not controlled in a mannet suitable to assure that activities were performed in accordance with documented procedures.
The resident Geotechnical Engineer issued four inter-office memos revising the technical requirements of specification SP-725-4549-00 for excavation and backfill work without formally revising the sub-ject specification. The inter-office memos revised the lift 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 as-surance review.
2.
10 CFR 50, Appendix B, Criterion XVII (Quality Assurance Records),
states, in part, that.
" sufficient records shall be maintained to furnish evidence of activities affecting quality."
CEI corporate Nuclear Quality Assurance Program 1700 requires in-spection records contain sufficient documentation to provide evidence of the work being performed in accordance with quality requirements.
Contrary-to the above, Creat 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.
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Appendix A In addition, the quality control inspection report was prepared and signed by a Quality Control Inspector other than the one who ob-served the work activity in progress.
3.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), 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 C500 requires ac-tivities affecting quality to be described and accomplished in accordance with instructions and procedures. Appropriate accept-ance 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 proce-dures:
a.
U.S. Testing Procedure QCP-10, section 1.2 requires that soil 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 after 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 fili, although moisture contents are required to be taken by the specification.
c.
Specification SP-225, sectico 1.06.7, states that when fill placement is less than 50 cubic yards per lift, density tests will be performed once every third lift. This is not an ap-propriaie quantitative acceptance criteria for determining that safety related backfill is being properly placed and com-pacted in each lift.
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