IR 05000329/1981001
| ML20003H078 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/20/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML20003H079 | List: |
| References | |
| NUDOCS 8105050065 | |
| Download: ML20003H078 (3) | |
Text
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Docket No. 50-329
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Consumers Power Coapany
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ATTN:
Mr. James 1/. Cook 6 u.a. %, %,
Vice President cca=ru e
.g Midland Project
1945 West Parnall Road b
Jackson, MI 49201 Gentlemen:
Thank you for your letter dated March 4, 1981, informing us of the action you have taken concerning the three items of noncompliance, the deviation and the unresolved item which we brought to your attention in Inspection Report No. 50-329/81-01; 50-330/81-01 forwarded by cur letters dated January 2, 1981 and January 5, 1981.
Regarding noncompliance iten. 81-01-01, we still perceive this matter as a valid item of nonco=pliance, and, as such, do not consider the corrective actions delineated in your letter to be fully responsive as described below.
1.
With respect to the first issue, the technical basis is that maximum soil density does not necessarily occur at maximum amplitude of the vibrating table. Therefore, one must determine at what amplitude maximum density occurs for a given soil type. To this extent, written instructions or procedures delineating methodology for achieving the requirements of the subject ASTM Standard D-2049 and any other such standards are required. An example of this consideration is referenced in the Corp. of Engineers Manual EM 1110-2-1906 dated November 30, 1970, Appendix XII, Page XII-8.
The corrective actions delineated in your letter for this issue are acceptable, and no additional response is required. We will examine l
these actions during a subsequent inspection.
2.
With respect to the second issue, the technical basis is that the gradation of the material may change during the compaction process.
Therefore, one must either take the relative density sample prior to compaction or run correlation tests on the material prior to and after compaction to demonstrate that there is no grain size change.
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Consumers Power Company-2-APR 7 0 * M
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The foregoing is necessary to establish a representative sample. The failure to consider this by the onsite geotechnical soils engineer was apparently an error. Such actions which affect quality should have been controlled by appropriate documented instructions.
The corrective actions delineated in your letter are unacceptable, and an additional response is required.
3.
With respect to the third issue, the technical basis is that quality control is performing in place density tests on a very limited basis to verify conformance with the specification requirements. The on-site geotechnical engineer's practice of performing in place density tests one foot below the surface for sand and 0.5 foot below the surface for clay appears to be acceptable. However, failure to document this methodology in an instruction or to maintain comprehen-sive records of this activity is in noncompliance with regulatory requirements.
The corrective actions delineated in your letter are unacceptable, and an additional response is required.
Therefore, we request that you submit a second letter to this office within 25 days of the date of this letter to respond to our concerns regarding noncompliance item 81-01-01 (second and third issues). Your response should be submitted under oath or affirmation and should include (1) corrective action taken and the results achieved; (2) corrective action taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.
Furthermore, we disagree with your statement on page 9 (last paragraph) of your response that adequate laboratory and field controls have been in i
existence for soil testing activities.
In fact, your response to 50.54(f)
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Question 23 (subsection 3.11, Inadequate Subcontractor Test Procedures)
states, "the procedures used for soil testing did not cover the following activities:
.(1 through 4)".
In addition, our inspection, which is
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the subject of this correspondence concluded that U.S. Testing still had not developed adequate procedures for laboratory and field soil testing activities.
With respect to your statement on page 10 of your response, we agree that the parenthetical phase (for other than NDE and soils) was omitted. However, U.S. Testing should have been required to demonstrate that testing procedures, equipment and personnel used for quality verification testing were capable of providing accurate test results.
If this had been verified as part of your corrective actions regarding the root causes of the settlement problem, we believe this noncompliance item could have been avoided.
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Consumers Power Company-3-AFE p e
- .s Regarding the discrepancies noted in the severity level for noncompliance items 81-01-01 and 81-01-02 as documented in the Inspection Report and Appendix A, the report is in error, and both items were considered to be Severity Level V.
Regarding noncos,11ance items 81-01-02 and 81-01-03, we have reviewed the additional information including your corrective actions and are in agree-ment that these matters do not constitute noncompliance with regulatory requirements. Therefore, our records will be revised to delete these matters as items of noncompliacce.
Regarding the deviation and the unresolved ites, your actions-will be reviewed during a subsequent inspection. Additionally, we understand, based on information provided by a member of your staff on April 8,1981, that the geotechnical engineer was present on the jobsite on January 19, 1981, instead of prior to this date, as stated on page 20 of your response.
Your cooperation with us is appreciated.
Sincerely,
5
</' James G. Keppler f
Director cc w/1tr dtd 3/4/81:
Central Files Reproduction Unit NRC 20b Resident Inspector, RIII PDR Local PDR NSIC TIC Ronald Callen, Michigan
Public Service Com=ission Myron M. Cherry
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