January 19, 2007 Mr. John Swailes, Vice President of Operations

January 19, 2007
Mr. John Swailes, Vice President of Operations
and Chief Nuclear Officer
National Enrichment Facility
P.O. Box 1789
Eunice, NM 88231
SUBJECT:
NRC INSPECTION REPORT NO. 70-3103/2006-001 AND NOTICE OF
VIOLATION
Dear Mr. Swailes:
This refers to the inspection conducted on December 11-14, 2006, in Eunice, New Mexico, at
Louisiana Energy Services’ National Enrichment Facility. The purpose of the inspection was to
evaluate Quality Assurance Program implementation and construction activities. The enclosed
report presents the results of this inspection.
This routine, announced inspection was an examination of activities conducted under your
license as they relate to safety and compliance with the Commission’s rules and regulations
and with the conditions of your license. Within these areas, the inspection consisted of
selected examination of procedures and representative records, observations of activities, and
interviews with personnel.
Based on the results of this inspection, the NRC has determined that a Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy included on the NRC’s Web site at www.nrc.gov; select What We Do,
Enforcement, then Enforcement Policy.
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding it are described in detail in the subject inspection report. The violation is
being cited in the Notice because it was identified by the NRC. We are concerned that you had
not fully established adequate controls for the ongoing activities and because inconsistent
implementation of your Quality Assurance program was noted.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. For your consideration and convenience, an
excerpt from NRC Information Notice 96-28, "Suggested Guidance Relating to Development
and Implementation of Corrective Action," is available on the NRC’s Web site. The NRC will
use your response, in part, to determine whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
NEF
2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response will be made available electronically for public inspection in the
NRC Public Document Room or from the NRC’s document system (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/readingrm/adams.html. To the extent possible, your
response should not include any personal privacy, proprietary, or safeguards information so
that it can be made available to the Public without redaction.
Should you have any questions concerning this letter, please contact us.
Sincerely,
/RA/
Mark S. Lesser, Chief
Construction Inspection Branch 1
Division of Construction Inspection
Docket No. 70-3103
License No. SNM-2010
Enclosures:
1. Notice of Violation
2. NRC Inspection Report 70-3103/2006-001
w/Attachments: 1. Key Points of Contact
2. Inspection Procedures and List of Items of Opened,
Closed and Discussed
3. List of Acronyms
4. List of Documents Reviewed
cc w/encls: (See next page)
NEF
cc w/encls:
Karl Gross, Licensing Manager
National Enrichment Facility
P.O. Box 1789
Eunice, NM 88231
Electronic Mail Distribution
James Curtiss, Counsel
Winston & Strawn
1700 K Street, NW
Washington, DC 20006
Electronic Mail Distribution
John Parker, Chief
Radiation Control Bureau
Field Operations Division
Environment Department
Harold S. Runnels Building
1190 St. Francis Drive, Room S 2100
P. O. Box 26110
Santa Fe, NM 87502
Richard A. Ratliff, PE, LMP
Radiation Program Officer
Bureau of Radiation Control
Department of State Health Services
Division for Regulatory Services
1100 West 49th Street
Austin, TX 78756-3189
Cindy Padilla, Deputy Secretary
New Mexico Department of Environment
Office of the Secretary
1190 St. Francis drive
P. O. Box 26110
Sante Fe, NM 87502-0157
Matt White, Mayor
City of Eunice
P.O. Box 147/1106 Ave J
Eunice, NM 88231
3
Monty D. Newman, Mayor
City of Hobbs
1203 Zuni St.
Hobbs, NM 88240
Gary Schubert, Chairman
Lea County Commissioners
100 North Main
Lovington, NM 88260
Reinhard Hinterreither, President
Louisiana Energy Services, L. P.
Electronic Mail Distribution
Dick Frazar, Vice President
Project Management
Electronic Mail Distribution
Jim Gearhart, Director
Quality Assurance
Louisiana Energy Services, L. P.
National Enrichment Facility
Electronic Mail Distribution
John Lawrence, General Counsel
Louisiana Energy Services, L. P.
Electronic Mail Distribution
Brenda Brooks, Director
Community Affairs and Government
Relations
Louisiana Energy Services, L. P.
Electronic Mail Distribution
Jana McNabb, Administrative Assistant
Louisiana Energy Services, L. P.
Electronic Mail Distribution
NEF
cc w/encls:
Karl Gross, Licensing Manager
National Enrichment Facility
P.O. Box 1789
Eunice, NM 88231
Electronic Mail Distribution
3
Monty D. Newman, Mayor
City of Hobbs
1203 Zuni St.
Hobbs, NM 88240
Gary Schubert, Chairman
Lea County Commissioners
100 North Main
Lovington, NM 88260
James Curtiss, Counsel
Winston & Strawn
1700 K Street, NW
Washington, DC 20006
Electronic Mail Distribution
Reinhard Hinterreither, President
Louisiana Energy Services, L. P.
Electronic Mail Distribution
John Parker, Chief
Radiation Control Bureau
Field Operations Division
Environment Department
Harold S. Runnels Building
1190 St. Francis Drive, Room S 2100
P. O. Box 26110
Santa Fe, NM 87502
Dick Frazar, Vice President
Project Management
Electronic Mail Distribution
Jim Gearhart, Director
Quality Assurance
Louisiana Energy Services, L. P.
National Enrichment Facility
Electronic Mail Distribution
Richard A. Ratliff, PE, LMP
Radiation Program Officer
Bureau of Radiation Control
Department of State Health Services
Division for Regulatory Services
1100 West 49th Street
Austin, TX 78756-3189
John Lawrence, General Counsel
Louisiana Energy Services, L. P.
Electronic Mail Distribution
Brenda Brooks, Director
Community Affairs and Government
Relations
Louisiana Energy Services, L. P.
Electronic Mail Distribution
Cindy Padilla, Deputy Secretary
New Mexico Department of Environment
Office of the Secretary
1190 St. Francis drive
P. O. Box 26110
Sante Fe, NM 87502-0157
Jana McNabb, Administrative Assistant
Louisiana Energy Services, L. P.
Electronic Mail Distribution
Matt White, Mayor
City of Eunice
P.O. Box 147/1106 Ave J
Eunice, NM 88231
Distribution w/encls:
M. Galloway, NMSS
B. Sm ith, NMSS
T. Johnson, NMSS
P. Silvia, NMSS
OE Mail
C. Evans, RII
M. Lesser, RII
# PUBLICLY AVAILABLE
ADAMS: # Yes
G NON-PUBLICLY AVAILABLE
RII:CIB1
via e-mail DAS
RII:CPB1
DAS
NAME
JTapia
DSeymour
1/18/07
E-MAIL COPY?
G SENSITIVE
#NON-SENSITIVE
ACCESSION NUMBER: ML070190661
OFFICE
SIGNATURE
DATE
J. Henson, RII
D. Seym our, RII
J. Tapia, RII
PUBLIC
YES
NO
OFFICIAL RECORD COPY
3.wpd
1/18/07
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
DOCUMENT NAME: S:\CIP\Inspection Reports\Fuel Facilities\LES - NEF\LES IR 2006-01 rev
NO
NOTICE OF VIOLATION
Louisiana Energy Services, L.P.
Eunice, New Mexico
Docket No. 70-3103
License No. SNM-2010
During an NRC inspection on December 11 through 14, 2006, a violation of NRC requirements
was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Special Nuclear Material License No. 2010 requires, in part, that the licensee shall
conduct authorized activities at the Louisiana Energy Services’ (LES) National
Enrichment Facility (NEF) in accordance with the statements, representations, and
conditions in the approved Quality Assurance Program Description dated April 9, 2004.
The LES NEF Quality Assurance Program Description states that “... the LES Quality
Assurance Program conforms to the criteria established in Title 10 of the Code of
Federal Regulations 10 CFR 50, Appendix B, Quality Assurance Criteria For Nuclear
Power Plants and Fuel Reprocessing Plants.” The criteria in 10 CFR 50, Appendix B,
are met by LES’s implementation of the American Society of Mechanical Engineers
(ASME) Quality Assurance (QA) standard NQA-1-1994, “Quality Assurance Program
Requirements for Nuclear Facilities,” including supplements as revised by the ASME
NQA-1a-1995 Addenda.
Contrary to the above, on and before December 14, 2006, LES NEF did not implement
ASME NQA-1-1994, as enumerated in the following examples:
a.
NQA-1 Basic Requirement 5, “Instructions, Procedures, and Drawings,” requires
that activities affecting quality be prescribed by and performed in accordance
with documented instructions, procedures, or drawings appropriate to the
circumstances. On four occasions, LES NEF failed to perform activities affecting
quality in accordance with documented instructions, procedures, or drawings
appropriate to the circumstances: (1) Prior to December 14, 2006, LES NEF
reviewed a contractor’s nonconformances, although LES NEF’s procedure or
instruction for this activity was not established; (2) Prior to December 14, 2006,
LES NEF approved two commercial grade dedication plans, although LES NEF’s
procedure or instruction for this activity was not established; (3) On December
14, 2006, LES NEF failed to follow specification requirement procedures for the
compaction of soil backfill; (4) On December 13, 2006, LES NEF failed to follow
procedures for the physical control of a nuclear density gauge.
b.
NQA-1 Basic Requirement 7, “Control of Purchased Items and Services,”
requires that services be controlled to assure conformance with specified
requirements. On and before December 13, 2006, LES NEF failed to assure
that the provider of on-site field and laboratory testing services had established
and documented methods in place for the identification and disposition of
nonconforming items.
c.
NQA-1 Basic Requirement 11, “Test Control,” requires that tests be controlled
with characteristics to be tested specified and acceptance criteria provided or
approved by the organization responsible for the design. On December 14,
Enclosure 1
NOV
2
2006, LES NEF failed to control the selection of acceptance criteria for field
density testing when field technicians, not part of the responsible design
organization, selected erroneous acceptance criteria.
d.
NQA-1 Basic Requirement 12, “Control of Measuring and Test Equipment,”
requires that measuring and test equipment used for activities affecting quality
be controlled. On and before December 13, 2006, LES NEF failed to control a
vernier caliper with an attached identifying number which could be used to verify
a valid calibration relationship to a nationally recognized standard.
This is a Severity Level IV violation (Supplement II)
Pursuant to the provisions of 10 CFR 2.201, Louisiana Energy Services, L.P. is hereby required
to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, D.C. 20555, with copies to the Chief, Technical
Support Group, Division of Fuel Cycle Safety and Safeguards, NMSS, and the Regional
Administrator, Region II, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a “Reply to a Notice of Violation” and
should include: (1) the reason for the violation, or, if contested, the basis for disputing the
violation, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previously docketed
correspondence if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an Order or Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other actions as may be proper should not be taken. Where good cause
is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room (PDR), or from the NRC’s document system (ADAMS), which is
accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html, to the extent
possible, it should not include any personal privacy, proprietary, or safeguards information so
that it can be made available to the public without redaction. If personal privacy or proprietary
information is necessary to provide an acceptable response, then please provide a bracketed
copy of your response that identifies the information that should be protected and a redacted
copy of your response that deletes such information. If you request withholding of such
material, you must specifically identify the portions of your response that you seek to have
withheld, and provide in detail the bases for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide the
information required by 10 CFR 2.390(b) to support a request for withholding confidential
commercial or financial information). If safeguards information is necessary to provide an
acceptable response, please provide the level of protection described in 10 CFR 73.21.
NOV
3
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated at Atlanta, Georgia
this 19th day of January 2007
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.:
70-3103
License No.:
SNM-2010
Report No.:
70-3103/2006-001
Licensee:
Louisiana Energy Services, L.P.
Location:
Eunice, NM
Inspection Dates:
December 11-14, 2006
December 22, 2006 (in-office review)
Inspectors:
Deborah A. Seymour, Senior Fuel Facility Inspector
Division of Construction Projects
Joseph I. Tapia, P.E., Senior Reactor Inspector,
Division of Construction Inspection
Accompanying Personnel:
Dean Foster, Environmental Scientist
State of New Mexico Environment Department
Department of Energy Oversight Bureau
Carlsbad Office
Approved:
Mark S. Lesser, Chief
Construction Inspection Branch 1
Division of Construction Inspection
Enclosure 2
EXECUTIVE SUMMARY
Louisiana Energy Services, L.P. National Enrichment Facility (LES NEF)
NRC Inspection Report 70-3103/2006-001
This announced inspection was a routine inspection of the licensee’s implementation of their
Quality Assurance (QA) program and of ongoing geotechnical/foundation activities. The
inspection identified the following aspects of the licensee’s programs as outlined below:
!
Methods for placement of excavation backfill, compactive effort, and testing were
adequately established. The results of laboratory tests on the stockpiled backfill material
were reviewed and found to be adequate. (Section 3)
!
Although Quality Level 1 work was ongoing at the Eunice site, the LES NEF QA
organization was minimally staffed and the LES NEF Quality Assurance Program was not
fully developed and in place. Inconsistent implementation of the QA programs was noted.
LES had not fully established adequate controls for ongoing soil backfill compaction and
testing activities. LES’ reliance on subcontractors was not sufficiently monitored to assure
that technical and QA requirements were met (Sections 2 and 3).
!
A violation was identified for several failures of LES NEF to conduct activities in
accordance with their approved Quality Assurance Program Description (QAPD). The
LES NEF QAPD requires conformance with 10 CFR 50, “Appendix B, Quality Assurance
Criteria For Nuclear Power Plants and Fuel Reprocessing Plants.” The criteria in
10 CFR 50, Appendix B, are met by LES’s implementation of the American Society of
Mechanical Engineers QA standard NQA-1-1994, “Quality Assurance Program
Requirements for Nuclear Facilities.” Following are the examples where NQA-1 was not
implemented:
Four examples of failures to meet NQA-1 Basic Requirement 5, “Instructions, Procedures,
and Drawings,” were identified. The first and second examples involved the failure to
have procedures in place for the review and approval of subcontractor identified
nonconformances and for approving contractors’ commercial grade dedication plans. In
the third example personnel failed to follow procedures for the compaction of soil backfill
when they used a water truck which was not in accordance with the specified method. In
the fourth example, personnel failed to follow procedures for the physical control of a
nuclear density gauge (Sections 2 and 3) .
One example of a failure to meet NQA-1 Basic Requirement 7, “Control of Purchased
Items and Services,” was identified because the supplier of field and laboratory testing
services did not have a documented method in place for the identification and submittal of
nonconforming items (Section 3).
2
One example of a failure to meet NQA-1 Basic Requirement 11, “Test Control,” was
identified because testing personnel were using incorrect acceptance criteria for the field
density testing of soil backfill (Section 3).
One example of a failure to meet NQA-1 Basic Requirement 12, “Control of Measuring
and Test Equipment,” was identified because a vernier caliper used for calibrating
laboratory test equipment did not have an attached identifying number which could be
used to verify a valid calibration relationship to a nationally recognized standard
(Section 3).
REPORT DETAILS
1.0
Summary of Site Activities
The licensee was implementing quality assurance (QA) requirements and soil backfill
activities during this inspection.
2.0
QA Program (Inspection Procedures (IPs) 88005, 88110 and 88115)
a.
Scope and Observations
The NRC had originally scheduled a QA team inspection for the week of December 11,
2006. That inspection was delayed because of delays in LES NEF’s activities. This
inspection was a limited scope review of LES NEF’s QA and construction activities.
The inspectors reviewed Louisiana Energy Services National Enrichment Facility’s (LES
NEF’s) QA program and organizational structure to verify that it was in accordance with
the requirements and organization structure delineated in LES NEF’s Quality Assurance
Program Description (QAPD).
Through discussions with the QA Director (QAD), the inspectors learned that the QA
Organization, at the time of this inspection, had a staffing level of five individuals, and was
in the process of hiring additional individuals. The five individuals were a combination of
LES NEF and contractor employees. Given the complexity of the project and the large
volume of work, ongoing and planned, the inspectors noted that this small number of
individuals posed a vulnerability to the effective operation of the QA Program. Issues
identified during this inspection supported this conclusion. During the discussions, the
inspectors learned that additional individuals were in the QA Program hiring pipeline.
Ultimately, LES NEF planned to establish a QA Program organization of eight to ten
individuals.
Section 1 of the QAPD lists the responsibilities of the QAD. The inspectors determined,
through discussions and review of documents, that the QAD reported directly to the LES
NEF President and was vested with the authority, access to work areas, and
organizational independence, to ensure that the requirements of the QAPD were properly
implemented.
One of the responsibilities of the QAD is QA technical support. This included maintaining
the QAPD and QA procedures. Based on discussion with the QAD, the inspectors
learned that the QAD was responsible for reviewing changes to the QAPD and QA
procedures, including determining what other organizations needed to review the
changes. A suite of procedures controlled the change process, and included:
QA-400, Revision 1, “Quality Assurance Program Description Changes,”
AD-1020, Revision 0, “Configuration Management Desktop Information,”
EG-101, Revision 0, “Configuration Change,”
AD-101, Revision 1, “Requirements for Procedures and DI’s.”
2
Through discussions and a document review, the inspectors learned that EG-101 was the
primary tool used for procedure, facility, and design changes. EG-101 required review of
these changes by several organizations, including: Health Safety and Environment,
Operations, Maintenance, Security, QA, etc. EG-101 was also used inappropriately to
review and evaluate nonconformance reports, project documents, and commercial grade
dedication plans (CGDPs), which are audits of a contractor’s QA plan. The inspectors
noted that AD-101, step 4.4.2 for revising a procedure, states, “Obtain change request
documents if required.” However, this procedure never defined when change request
documents were not required. This would indicate that change request documents were
required for any procedure change, including a very minor change (correcting spelling,
etc.).
The QAPD also lists the administration of the corrective action and nonconformance
processes as one of the technical support responsibilities of the QAD. Through
discussions, the inspectors learned that LES NEF audited their contractor’s corrective
action program, and that LES NEF will review and approve nonconformances identified by
the contractor. At the time of this inspection, LES NEF did not have a finalized procedure
or instruction controlling the review and approval process of the contractor identified
nonconformances. The review and approval process was performed and documented
using an informal process. LES NEF planned on having this instruction in place by the
end of 2006. At the time of this inspection, the contractor and their subcontractor were
performing activities affecting quality (Quality Level 1 activities), including backfilling and
instrument calibrations.
American Society of Mechanical Engineers (ASME) NQA-1-1994 Edition, “Quality
Assurance Requirements for Nuclear Facility Applications,” Basic Requirement 5,
“Instructions, Procedures, and Drawings,” states, in part, that activities affecting quality
shall be prescribed by and performed in accordance with documented instructions,
procedures, or drawings appropriate to the circumstances. LES, by their license
documentation, is required to implement NQA-1. The failure of LES NEF to have a
procedure or instruction in place for reviewing contractor noncompliances was one
example of Violation (VIO) 70-3103/2006-001-01, “Failure to Fully Implement NQA-1.”
As part of this review the inspectors also attended a Corrective Action Program Screening
Committee Meeting. The inspectors noted that the discussions were in-depth and
probing. No issues were identified.
The QAPD also lists the QA technical review of procurement documents as one of the
technical support responsibilities of the QAD. LES NEF did not have a procedure for this
task. LES NEF’s philosophy was that the contractor was responsible for procurement of
materials and services for the construction project. Given this, LES NEF planned to audit
the contractor’s audits and surveillances. At the time of this inspection, LES NEF had not
reviewed the contractor’s procurement procedures, other than their CGDP. LES NEF had
reviewed the contractor’s review of the subcontractor’s QA program, and LES NEF had
identified deficiencies in the review and QA program. LES NEF proposed actions to be
taken by the contractor and subcontractor to correct the deficiencies. At the time of this
inspection, LES NEF had not verified that these actions were complete.
3
Based on discussions with the licensee, the inspectors learned that LES NEF had
approved two CGDPs using an informal process, and had eleven more waiting for
approval. Through these discussions with the licensee, the inspectors determined that
LES NEF needed to define a procedure or instruction to clarify the approval process for
contractor CGDPs. The failure of LES NEF to have a procedure or instruction in place for
the approval process for contractor CGDPs was one example of VIO 70-3103/2006-00101, “Failure to Fully Implement NQA-1.”
The QAPD also lists the review and concurrence of changes to items relied upon for
safety (IROFS), items that could affect the functions of IROFS, and items required to
satisfy regulatory requirements for which QA Level 1 requirements are applied, as one of
the technical support responsibilities of the QAD. Through discussions with the QAD, the
inspectors learned that this function is performed by the involvement of the QAD in the
cross disciplinary review of changes as controlled by EG-101.
The QAPD also lists the administration of the auditor and lead auditor certification process
as one of the technical support responsibilities of the QAD. The inspectors determined
that LES NEF has one individual certified as an auditor. The inspectors reviewed selected
portions of QA-202, “Auditor Qualification and Certification,” Revision 0, and this
individual’s qualification and certification records, and found them to be adequate..
The QAPD also lists the QA review of project documents as one of the technical support
responsibilities of the QAD. The QAD indicated that this task was accomplished by using
EG-101, AD-101, and PR-101, “LES NEF Control of Procurement,” Revision 2. The LES
NEF licensing organization had generated a list of commitments from the license
application documents and was in the process of refining the list. LES NEF planned to
revise Procedure AD-101 to formalize how these commitments are identified in various
documents.
The QAPD also lists the oversight of documents and records control as one of the
technical support responsibilities of the QAD. Through discussions with the licensee, the
inspectors determined that this was going to be accomplished using AD-101 and audits
and surveillances.
b.
Conclusions
Based on this review, the inspectors concluded that, although Quality Level 1 work was
ongoing, the QA Program was not fully developed and in place. Specifically, LES NEF did
not have all required procedures and instructions formalized and implemented for the
ongoing activities. Two examples of a failure to meet NQA-1 Basic Requirement 5,
Instructions, Procedures, and Drawings, were identified (VIO 70-3103/2006-001-01,
“Failure to Fully Implement NQA-1"). The inspectors also noted that the LES NEF QA
organization was minimally staffed.
4
3.0
Geotechnical/Foundation Activities (IP 88131)
a.
Scope and Observations
An inspection of geotechnical/foundation activities was conducted to verify that the
technical and QA requirements detailed or referenced in the licensing basis had been
adequately defined in the construction specifications, drawings, and related procedures.
The adequacy of programmatic controls was evaluated through a review and assessment
of the QA program implementation. Ongoing work and quality control was assessed
through direct observation and independent evaluation of backfill placement and testing.
This inspection was conducted to ensure that work activities were accomplished in
accordance with the design specifications, applicable standards and procedures and that
records accurately reflected work accomplishment consistent with those requirements.
The inspection also served to assess the effectiveness of the corrective action program as
it related to the identification and resolution of problems in the geotechnical area.
The licensee’s contractor was expected to implement the technical and QA requirements
for the construction of buildings, including the required excavations and placement of soil
backfill. The contractor had completed excavation and subgrade proof-rolling for Building
1300 prior to this inspection. Activities that were in progress during this inspection
included removal of unsatisfactory material identified during proof-rolling, placement and
compaction of backfill material and testing of compacted backfill. Excavation of other
building areas and stockpiling of the excavated material for subsequent use as backfill
along with acceptance testing was also underway.
(1) Procedures
Specification No. 114489-S-S-02300-3, “Clearing, Grading, and Earthwork Material,
Construction, And Testing,” defined the technical requirements necessary for achieving an
adequate foundation for site buildings. In order to implement these requirements, the
contractor developed Work Plan No. 1300-CA/CA2-CI-001, “Site Excavation and Backfill Building 1300 Centrifuge Assembly Building (CAB).” The inspectors reviewed both
documents and found that the methods for placement of the backfill, compactive effort,
and testing were adequately established. The specification required completion of
compaction test pads to establish maximum loose lift thickness, type of compaction
equipment, and number of passes to achieve the required density. The specification also
specified the testing requirements for the backfill and included gradation, specific gravity,
in-place density, moisture density relationships, and moisture content. The American
Society for Testing and Materials (ASTM) test procedures and frequency of testing were
adequately specified. A review of related drawings and procedures used for the control of
excavations, placement of backfill, and quality control activities was also conducted. The
review served to verify that procedures prescribed adequate construction methods for the
control of excavations, foundation verification (proof-rolling), sub-grade preparation,
placement of backfill, and quality control testing.
5
The inspectors reviewed the results of three plate load tests conducted to determine the
deformation modulus of the compacted backfill. These tests were required because they
provided a measure of the elastic response and expected differential settlement of
buildings. Differential settlements are critical to the operation of this facility. The test was
constructed using the same equipment, materials, and techniques intended to be used
during construction. The compacted backfill was developed with 8-inch lifts and a 95%
maximum dry density. The plate load test used a 30-inch diameter bearing plate to verify
an adequate subgrade reaction or stiffness. The results of these tests verified that the
value assumed for Young’s modulus of the compacted backfill in the design was
conservative. The value for Young’s modulus relates to the static stress-strain analyses
used in the design of the building foundations. The design assumed that the backfill
material, compacted to a dry density of at least 95% of the Modified Proctor (ASTM
D1557) maximum dry density, would have a Young’s modulus of 300 thousand pounds
per square foot (ksf). The plate load tests results were all above this value. The tests
also verified that an increase in density and a decrease in compressibility was achieved by
the compaction effort.
(2) Observation of Work
The inspectors observed ongoing backfilling of over-excavated areas identified during
proof-rolling. Work was required to be in accordance with contractor Work Plan No.
1300-CA/CA2-CI-001, “Site Excavation and Backfill - Building 1300 Centrifuge Assembly
Building (CAB).” This document referenced Specification No. 114489-S-S-02300-3,
“Clearing, Grading, and Earthwork Material, Construction, And Testing.” Section 3.23 of
this specification required that compaction of backfill be accomplished using industryaccepted heavy tamping rollers, heavy rubber-tired rollers, heavy vibratory compactors, or
heavy drum rollers. Contrary to this requirement, the inspectors observed compaction of
backfill using a water truck. The use of a water truck for the compaction of backfill was
not in accordance with the specified method and represented a failure to follow required
procedures for the compaction of soil backfill.
ASME NQA-1-1994, Basic Requirement 5, “Instructions, Procedures, and Drawings”
requires that activities affecting quality be performed in accordance with documented
procedures. The failure to follow procedures for the compaction of backfill was one
example of VIO 70-3103/2006-001-01, “Failure to Fully Implement NQA-1.”
(3) Laboratory
The inspectors examined the on-site soil testing laboratory. Test equipment was
inspected and laboratory technicians were interviewed. Copies of ASTM test procedures
were available in the laboratory. Laboratory equipment was in good condition and in
current calibration with one exception. A vernier caliper, serial number 700 0 654, did not
have an attached identification number which corresponded to available calibration
records. ASME NQA-1-1994, Basic Requirement 12, “Control of Measuring and Test
Equipment,” requires that measuring and test equipment used for activities affecting
quality be controlled. The subject vernier caliper was previously used for calibrating a
variety of laboratory test equipment. The failure to have an attached identifying number
6
which could be used to verify a valid calibration relationship to a nationally recognized
standard was one example of VIO 70-3103/2006-001-01, “Failure to Fully Implement
NQA-1.”
The inspectors observed the following laboratory calibration activities:
•
•
•
•
Volume Calibration of 4-inch Proctor Moisture-Density Specimen Mold by the
Linear Measurement Method
Volume Calibration of 4-inch Proctor Moisture-Density Specimen Mold by the
Water Filled Method
Volume Calibration of 6-inch Proctor Moisture-Density Specimen Mold by the
Linear Measurement Method
Volume Calibration of 6-inch Proctor Moisture-Density Specimen Mold by the
Water Filled Method
Laboratory technicians were knowledgeable and experienced in the performance of the
observed calibrations.
During the tour of laboratory facilities, the inspectors noted that Troxler nuclear density
gauge serial No. 37041 was not in the required and secure storage locker. A review of
the Troxler gauge utilization log indicated that the particular gauge was not logged out and
therefore should have been in the required location. The gauge was subsequently located
on site in a locked box in the bed of a subcontractor’s truck. The subcontractor’s
Operating and Emergency Procedures - “Handling Procedure” requires that personnel use
the Troxler gauge utilization log every time a gauge is taken out of its secure storage
location and when it is returned. ASME NQA-1-1994, Basic Requirement 5, “Instructions,
Procedures, and Drawings” requires that activities affecting quality be performed in
accordance with documented procedures. The failure to follow procedures for the
physical control of a nuclear density gauge was one example of VIO 70-3103/2006-00101, “Failure to Fully Implement NQA-1.”
The material used for backfill was obtained from onsite stockpiles. During the inspection,
the results of laboratory tests on the stockpiled backfill material, which included particle
size analysis, maximum dry density, moisture content, specific gravity, and liquid limit
plasticity determinations, were reviewed and found to be adequate.
(4) Quality Control
The inspectors observed preparations for field density testing by the nuclear method in
areas that had been backfilled after over-excavation due to proof-rolling. The
subcontractor’s testing personnel had filled out a Field Density Test Report Form with
acceptance criteria obtained from a “Proctor Summary Report.” The Report listed the
results of several Modified Proctor laboratory tests for the determination of the maximum
dry density of soil (ASTM D1557). Technicians had incorrectly selected the results of a
laboratory test performed on a sample previously obtained during excavation from the
center of building 1300 (Lab No. S00005). The value selected was 113.0 pounds per
cubic foot (pcf). The correct sample should have been the source of the backfill material,
7
the west recovery pile (Lab No. S00032). The correct acceptance criteria should have
been 124.5 pcf. The incorrect acceptance criteria was nonconservative and may have
resulted in the acceptance of field densities lower than specified.
The “Proctor Summary Report” was not a controlled document as further evidenced by the
fact that the contractor quality control inspectors were in possession of a copy of the same
document, however theirs listed additional laboratory test results. The selection of the
incorrect acceptance criteria for the field density testing of backfill resulted because the
process allowed technicians to select the criteria from an uncontrolled document without
adequate oversight or direction from the responsible engineering organization. ASME
NQA-1-1994, Basic Requirement 11, “Test Control” requires that tests be controlled with
characteristics to be tested specified and acceptance criteria provided or approved by the
organization responsible for the design. The failure to control field density testing and
provide correct acceptance criteria was one example of VIO 70-3103/2006-001-01,
“Failure to Fully Implement NQA-1.”
A review was conducted of the CGDP used by the contractor to accept the subcontractor
for field laboratory testing services. The contractor conducted a supplier survey at the
subcontractor’s offices in Albuquerque, NM. The survey was a review of the
subcontractor’s QA Program and was intended to verify that the subcontractor was
qualified and capable of providing laboratory testing services. During this inspection,
nonconforming items were identified related to a failure to follow procedures for the
physical control of a nuclear density gauge and a failure to control measuring and test
equipment. The subcontractor’s laboratory manager indicated that nonconformance
reports would be generated for each nonconformance. A subsequent request for copies
of the nonconformance reports disclosed that one issue had been documented on an
employee disciplinary form and the other issue was documented on a handwritten piece of
paper. The inspectors determined that the on-site laboratory did not have a
nonconformance procedure or document in place. While the contractor CGDP process
reviewed the subcontractor at the Albuquerque office, a verification of adequacy was not
conducted at the site as evidenced by the lack of a nonconformance procedure and
document. Consequently, the contractor did not identify that the subcontractor did not
have the required QA documents in place and was not prepared to conduct quality related
work. ASME NQA-1-1994, Basic Requirement 7, “Control of Purchased Items and
Services,” requires that services be controlled to assure conformance with specified
requirements. The failure to ensure that the supplier of field and laboratory services had
established and documented methods in place for the identification and disposition of
nonconforming items, was one example of VIO 70-3103/2006-001-01, “Failure to Fully
Implement NQA-1.”
b.
Conclusions
The methods for placement of the backfill, compactive effort, and testing were adequately
established. The results of laboratory tests on the stockpiled backfill material were
reviewed and found to be adequate.
8
Based on the number of examples of a failure to implement the guidelines of ASME NQA1-1994, “Quality Assurance Requirements for Nuclear Facility Applications,” the
inspectors determined that the licensee had not fully established adequate controls for
ongoing soil backfill compaction and testing activities. In addition to the examples noted,
inconsistent implementation of the applicable QA programs was noted.
Subsequent to inspectors’ identification of a failure to follow procedures for the physical
control of a nuclear density gauge and a failure to adequately control a vernier caliper, the
contractor entered both issues in their QA program. The nuclear density gauge issue was
documented on a Deficiency Report and the vernier caliper issue was documented as a
reject on a Surveillance Checklist. While both issues represented nonconforming
conditions, the contractor used different methods to address them. The inspectors noted
that the inconsistent method of documentation had the potential for the issues to receive
different resolution.
The failure to utilize the correct acceptance criteria for field density testing and the failure
to follow procedures for the compaction of backfill could be attributed to a lack of
adequate oversight. The licensee’s reliance on subcontractors was not sufficiently
monitored to assure that technical and QA requirements were met. The failure to ensure
that the on-site testing laboratory had an effective QA program in place was a prime
example of this deficiency.
4.0
Exit Meeting
The inspection scope and results were summarized on December 14, 2006, and on
January 4, 2007, by telephone, with the licensee. The inspectors described the areas
inspected and discussed in detail the inspection results. Although proprietary documents
and processes were reviewed during this inspection, the proprietary nature of these
documents or processes is not included in this report. No dissenting comments were
received from the licensee.
KEY POINTS OF CONTACT
Licensee Personnel
M. Bogre, Licensing, LES NEF
R. Frazer, Vice President- Project Management, LES NEF
J. Freels, Licensing, LES NEF
J. Gearhart, Quality Assurance Director, LES NEF
K. Gross, Licensing Manager, LES NEF
R. Hinterreither, President, LES NEF
G. Sanford, Director, Support Services Director, LES NEF
J. Swailes, Vice President-Operations
Other Contract Personnel
T. Albright, Assistant Construction Project Manager
R. Bennett, Assistant Construction Manager
T. Burkhard, Construction Manager
S. Boayake, P.E., Senior Consultant
S. Cotney, Assistant Construction Project Manager
T. Wills, Project Quality Manager
Other licensee employees contacted included engineers, technicians, contractors,
subcontractors, and office personnel.
Attachment 1
INSPECTION PROCEDURES USED
IP 88005
IP 88110
Management Organization and Controls
Quality Assurance: Problem Identification, Resolution and Corrective
Action
Supplier/Vendor Inspection (Construction Phase)
Geotechnical/Foundation Activities
IP 88115
IP 88131
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Item Number
Status
Description
VIO 70-3103/2006-001-01
Opened
Failure to Fully Implement NQA-1-1994,
“Quality Assurance Requirements for Nuclear
Facility Applications” (Sections 2 and 3)
Attachment 2
LIST OF ACRONYMS USED
ADAMS
ASME
ASTM
CAB
CFR
CGDP
IP
IROFS
LES
NEF
No.
pcf
QA
QAD
QAPD
Rev.
SL
VIO
Agency-Wide Document Access and Management System
American Society of Mechanical Engineers
American Society for Testing and Materials
Centrifuge Assembly Building
Code of Federal Regulations
Commercial Grade Dedication Plan
Inspection Procedure
Item Relied on for Safety
Louisiana Energy Services, L. P.
National Enrichment Facility
Number
Pounds Per Cubic Foot
Quality Assurance
Quality Assurance Director
Quality Assurance Program Description
Revision
Severity Level
Violation
Attachment 3
LIST OF DOCUMENTS REVIEWED
Specifications and Procedures
Nuclear Technology Solutions Specification Number (No.) 114489-S-S-02300-3,
“Clearing, Grading, and Earthwork Material, Construction, And Testing,” dated
November 27, 2006
LES Procedure No. EG-101-1002, Revision (Rev.) 0, “Processing Field Change Requests
(FCRs) and Requests For Information.”
LES Procedure QA-400, Rev. 1, “Quality Assurance Program Description Changes,”
LES Desktop Instruction AD-1020, Rev. 0, “Configuration Management Desktop
Information,”
LES Procedure EG-101, Rev. 0, “Configuration Change,”
LES Procedure AD-101, Rev. 1, “Requirements for Procedures and DI’s,”
LES Procedure PR-101, Rev. 2, “LES NEF Control of Procurement,”
LES Procedure QA-202, Rev. 0, “Auditor Qualification and Certification,”
Contractor Procedure No. PSP 07.09, Rev. 0, “Field Change Request and Requests for
Information.”
Contractor Procedure No. PSP 09.04, Rev. 2, “Commercial Grade Dedication.”
Contractor Procedure No. PSP 11.01, Rev. 0, “Work Plans.”
Contractor Procedure No. PSP 15.01, Rev. 0, “Identification and Control of Deviations.”
Contractor Standard Procedure No. 2.3, Rev. 3, “Qualification/Certification of Inspection
and Test Personnel.”
Contractor Work Plan No. 1300-CA/CA2-CI-001, Rev. 0, “Site Excavation and Backfill Building 1300 Centrifuge Assembly Building (CAB).”
Miscellaneous Documents
NEF Assessment Report, “Backfill, Compaction, and Related Civil Construction Readiness
Assessment,” November 6-17, 2006.
Nuclear Technology Solutions Report No. 114489-G-01, Rev. 0, “Geotechnical Report for
The National Enrichment Facility in Lea County, New Mexico.”
Attachment 4
2
LES Condition Report 2006-0040, dated December 1, 2006.
LES Condition Report 2006-0041, dated December 2, 2006
Contractor Commercial Grade Evaluation Screening Worksheets for the Plate Load
Testing, pages 1-50 (P.O. 28683-PO-6049).
Contractor Commercial Grade Dedication Plan 28683-CGDP-0001, “Civil Laboratory and
Testing Services,” dated December 1, 2006.
Contractor Request for Information 28683-061, “Over Excavation Requirements and
Limits,” dated December 7, 2006.
Contractor Request for Information 28683-045, “Civil - Proofrolling,” dated November 9,
2006.
Contractor Deficiency Report No. 12, dated December 20, 2006.
Contractor Surveillance Checklist No. SC-01410, “Testing Lab Services (QA Level 1
and 3).”
Subcontractor Construction Materials Laboratory Quality Assurance Program, Rev. 12.
Subcontractor Form, “Field Density Test (Nuclear Method) ASTM (D2922, D3017, &
D2950),” Rev. 5.
Attachment 4