ML19347E172

Responds to NRC 810210 Ltr Re Violations Noted in IE Insp Rept 50-461/81-03.Corrective Actions:All Unidentified &/Or Untraceable Hanger Flat Plate Matl,Including Sheared Plates, Removed from Electrical Hanger Fabrication Areas

ML19347E172
Person / Time
Site:	Clinton
Issue date:	03/06/1981
From:	Koch L ILLINOIS POWER CO.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19347E171	List: ML19347E172
References
U-0221, U-221, NUDOCS 8104240174
Download: ML19347E172 (4)

Text

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0981-L u-0221

' .O . ILLINDIS POWER COMPANY .

Q37-81(03-06)-L J soo Source 27TH STREET DECATUR, ILLINOIS 62525 March 6, 1981 Mr. R. F. Heishman, Acting Director Division of Resident and Project Inspection U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Heishman:

This is in response to your Notice of Violation and Inspection Report Number 50-461/8;-03. Illinois Power Company's response for the two items of noncompliance cited is as follows:

1. Control of Special Processess The Notice of Violation states, in part:

"Contraty to the above, a 12 inch lift of concrets was poured in the Category I Diesel Generator Building floor without sandblast cleaning and removal of the curing compound from the construction joint surface."

ACI Standard 301-72 (Revised 1973), " Specification for Structural Concrete for Building," sections 6 and 11 address the preparation of construction joints. Furthermore, Sargent and Lundy (S&L) Specification K-2944, " Concrete and Grout i

Work", section 304, similarly addresses the preparation of construction joints that : require positive bonding between existing and new concrete.

The notice of violation erroneously assumes that the 12 inch lift of conrete poured in the diesel generator building formed a construction joint and required bonding. The surface comprising the joint between the structural base slab and the separate floor finish concrete slab is not a construction joint as described by ACI Stendard 301-72, nor is it intended to be defined as .a construction joint in Sepcification K-2944. Positive bonding of the joint in question is not structurally required. The base slab is designed to support all loads imposed upon it, resist shear and flexural stresses caused by those loads, and does not rely upon any additional strength that may be gained from the presence of a separate floor finish slab.

The requirements for the preparation of base slab surface prior to the placement of separate concrete floor finishes is Bi104 #

Wks 12 HNM

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Mr. R. F. Heishman March 6, 1981 NRC Page 2 s

addressed in S&L specification K-2944, section 303.3, which states in part, " Thoroughly clean base slab of all foreign matter, oil, grease, etc. , before finish floor is placed, but do not chip base slab unless necessary for removal of oil or '

grease, etc." This section of the specification does not discut s the removal of curing compound, the substance in question in the written violation.

On November 13, 1979, prier to placement of any floor finish concrete, a clarification of the section 308.3 of S&L specification K-2944 was requested of and provided by Sargent and Lundy. Clarification provided in meeting notes states, "BA noted that ECN 1307 does not address the removal of laitance and curing compound as a part of the base slab prepara-tion prior to the finish slab pour. S&L advised that they had not intended to address the removal of laitance and curing compound, but it was their interpretation that it was not necessary. BA will address the surface preparation prior to finish slab pours in their BAP and thus not require a change to the specification."

Subsequently, proj ect procedure, BAP 3.1.1 " Concrete" was changed to clearly address the surface preparation require-ments. BAP 3.1.1, paragraph 5.6.6e) reads , Base slab to be thoroughly clean of all foreign matter, oil, grease, etc.

NOTE: Curing compound need not be removed as per Architect Engineer."

The procedural change was subsequently submitted to Sargent and Lundy who reviewed the procedure against the requirements of the specification K-2944 and accepted the procedure without exception.

At the tLae the inspector's concetns were raised, a Field Engineering Change Notice (FECN 138) to specification K-2944 was prepared and approved by Sargent and Lundy to more clearly define the requirements pertaining to preparation of base slab concrete prior to placement of separate floor finish concrete.

"The removal of curin This not notice states in part, required unless noted on the design drawings.g compound is Furthermore, two letters have been written by Sareent and Lundy to Illinois Power which provide further clari- :ation to i the effect that (1) this type of joint in question is not a construction joint, (2) that positive bonding is not structurally required, and (3) that the curing compound for such floor finishes does not necessarily need to be removed.

! Illinois Power contends that the base slab preparation for

! the subj ect placement was and is in compliance with the proj ect specification, approved procedures, and stendards. We take l

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Mr. R. F.' Heishman March 6, 1981 NRC Page 3 exception to the violation and feel that no corrective action or further clarification of this matter is necessary.

2. Identification and Control of Materials, Parts and Components The Notice of Violation states, in part:

, " Contrary to the above, non-traceable steel plate material

, is installed in some electrical hanger assemblies in the 4

Auxiliary, Diesel Generator, and Control Buildings.

Traceability and identification transfer during fabrication appears to be uncontrolled. Quality Control has not assured the recording of traceability identification of the subject steel plate in all cases."

The inspector's concern dealt with " sheared" filler plates ,

used in electrical hanger fabrication. " Sheared" filler places are those plates ordered to specific sizes and material speci-fications and are cut by a manufacturer 's shear. Project procedure BAP 1.5, Material Identification, paragraph 4.12.8 states, "Small miscellaneous structural steel material received 4

in bulk containers (such as sheared filler plates) shall have the RIR number recorded on the shipping container. Traceability shall be maintained until issued to the field for construction."

Thus, traceability is only maintained until such thre~as the material is issued to the field for fabrication. This is consistent with other material installations of bulk commodities.

For other safety related plate material, which is not bulk, either the heat number or the RIK number marked on the material provides appropriate traceability.

As noted by the inspector, the process of controlling sheared plates traceability during fabrication and installation needs greater attention. As a result, the following corrective action

, has been taken:

1. All unidentified and/or untraceable hanger flat plate material (including sheared plates) was removed from electrical hanger fabrication areas.

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2. Controlled electrical fabrication areas have been

. established with signs or flags identifying the areas.

3. A meeting with foreman and general foreman was held to discuss plate traceability requirements.

4. Scrap barrels, labeled as such, have been stationed at each electrical fabrication area.

i 5. Closed out electrical travelers are being reviewed

again by Quality Control to insure that the traveler

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. Mr. R. F. Heishman March 6, 1981 NRC Page 4 inspection checklists (reports) appropriately identify sheared plate installations. Unique traceability of sheared plates is not required.

6. A Quality Control surveillance program has been established and implemented to assure that personnel in the electrical fabrication areas are transferring heat /RIR numbers when plate material is divided and that no unidentified pieces are lying around.

In order to prevent future noncompliances of this nature, the following action is in the process of being taken.

1. Project procedure BAP 1.5, Material Identification, paragraph 4.5 will be revised to clarify traceability requirements for sheared plates and other safety related plate material.

2. Proj ect procedure , BAP 3. 3.6, Electrical Raceway Support Installation, is being revised to clearly distinguish that sheared plates are treated differently from other plate material regarding material trace-ability. Further, the procedure is being revised to clarify the Quality Control verification function regarding sheared plate material.

It is expected that all corrective action to this item of nonco=pliance will be completed by March 30, 1981.

I trust that our response is satisfactory to allow cl:se out of these two icecs when all action is complete. I hereby affirm that the information contained in this letter is correct to the best of my knowledge.

Sincerely,

/?dM ,

. J. Koch Vice President cc: H. H. Livermore, NRC Resident Inspector Director, Quality Assurance CPS /DRC kw- --' - , - -- + , , - - + n -n-e