ML20053D141

Responds to NRC 810413 Ltr Re Violations Noted in IE Insp Rept 50-461/81-03.Corrective Actions:Specs & Procedures Re Preparation for Finished Floors Being Clarified.Matl Identification Procedure Being Revised

ML20053D141
Person / Time
Site:	Clinton
Issue date:	06/01/1981
From:	Koch L ILLINOIS POWER CO.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20053D136	List: ML20053D141
References
0981-L, 981-1, 981-L, U-0239, U-239, NUDOCS 8206040119
Download: ML20053D141 (3)

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0981-L U-0239

/LLIN0/S POWER 00MPANY q37_gt(og_ot)_t 73 V{

c 500 SOUTH 27TH STREET, DECATUR. ILLINOIS 62525 June 1, 1981 _

Mr. R.F. Heishman, Acting Director Director of Resident and Project Inspection U.S. Nuclear Regulatory Commission Region III hl OD 799 Roosevelt Road Glen Ellyn, IL 61037

Dear Mr. Heishman:

This is.in response to your Notice of Violation an'd Inspection Report 50-461/81-03. Our response is being resubmitted in accor-dance with your letter request dated April 13, 1981.

-Our response for the two items of noncompliance cited in Report 50-461/80-03 is as follows:

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

" Contrary to the above, a 12-inch lift of concrete was poured in the Category I Diesel Generator d Building floor without sandblast c.:.aaning and -

removal of the curing compound from the construc-tion joint surface."

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

" Concrete and Grout Work", Section 304, similarly adresses the preparation of construction joints that require positive bonding between existing and new concrete.

We requested Sargent & Lundy to review the general practice of pouring finish floors at CPS. S&L particularly concentrated on requirements for surface preparation and cleaning prior to pouring the finish floors. S&L determined that there are no significant seismic-induced shear loads or uplift loads which could cause problems because of the construction practices at CPS. More specifically, sandblast cleaning and removal of curing compound are not required.

We have found that the specifications and procedures associated with the preparation for finished floors may have been confusing. Consequently, we have taken corrective action n

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, Mr. R.F. Heishman June 1, 1981 NRC Page 2

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to clarify the specifications, procedures and related practices.

Field Engineering Change Notice (FECN) No. 138 has been issued to provide additional guidance and interpretation of S&L's specification K-2944, " Concrete and Grout Work." We believe that as a result of the detailed Sargent and Lundy review and the specification revision, that we are now in full compliance with applicabic regulatory requirements for control of finish floor concrete pours.

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 Auxiliary, Diesel Generator, and Control Buildings.. Traceability and identifica-tion transfer during fabrication appear 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 filler plates used in 1 electrical hanger fabrication. These filler plates are

[\s_- functionally used as either spacer material or structural tie plates in the construction of electrical raceway supports ~

at Clinton. When safety related plate material'is divided for use in the field, it is to be marked with either its heat number or Receiving Inspection Report (RIR) number. Transfer of such identification is accomplished prior to any cutting operations.

Proj ect procedure BAP l'.5, Material Identification, paragraph 4.12.8, states: "Small miscellaneous structural steel material received in bulk containers (such as sheared filler plates) shall have the RIR number recorded on the shipping container. Trace-ability shall be maintained until issued to the field for construction." This is consistentwith other material installa-tions of bulk commodities at CPS in that we have very high con-fidence that proper bulk materials are received at the site and that only these materials are then issued to the field for con-struction. We have evumuated unique piece traceability for sheared filler plates as impractical and not required for this application. While we recognize that unique traceability is necessary on other commodities, it is not necessary for this

material. Further, the increased cost to achieve unique

traceability of sheared filler plate does not provide any sig-nificant improvement in quality assurance.

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'Mr. R.F. Heishman June 1, 1981

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, We have determined.that our procedures for material traceability which were in effect at the time of the Notice .

of Violation needed some changes. As a result the following corrective action was taken by March 30, 1981.

a. Project procedure BAP 1.5, Material Identification, was revised to clarify traceability requirements for safety

. related plate material.

b. Project procedure BAP 3.3.6, Electrical Raceway Support Installation was revised to clearly distinguish'that sheared plates are treated differently from other plate material regarding traceability.

c. A meeting with foremen and general foremen was held to discuss plate traceability requirements.

-I trust that our response is satisfactory to allow close

{ out of these two issues of concern. I hereby affirm that the information contained in this letter is correct to the best of my knowledge.

Sincerely, N

I L.J. Koch Vice President AJB/prh cc: H.H. Livermore, NRC Resident Inspector Director, Quality Assurance i.

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