ML19241B522
| ML19241B522 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/25/1979 |
| From: | Stello V Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19241B520 | List: |
| References | |
| DD-79, DEC-790625, NUDOCS 7907180803 | |
| Download: ML19241B522 (8) | |
Text
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DD-70 UNITED STATES OF AMERICA NUCLEAR REGUI.ATORY CO.TfISSION CFFICE OF INSPECTION AND EhTORCEMENT Victcr Stello, Jr., Director In the Matter of VIRGINIA ELECTRIC & POWER Co.
Docket. Nos. 50-338 (North Anna Pcwer Station, 50-339 (2.206)
Units 1 and 2)
DIRECTOR'S DECISION UNDER
'_0 CFR 2.206 REQUEST FOR ENFORCEMENT ACTION By letter dated November 1,1978, June Allen on behalf of t'he North Anna Environmental Coalition (NAEC) requested that the Nuclear Regulatory Commissicn revoke the operating licenses issued to tha Virginia Electric and Power Company (VEPCO) for the North Anna Power Station, Units 1 and 2, as an enforcement saaction for material false statements stemming from VEPCO's alleged failure to timely report information concerning settlement of foundations at the North Anna site. This letter is being treated as a rbquest for action pursuant to 10 CFR 2.206 of the Commission's regulations.
Notice of receipt of this request was published in the Federal Recister on December 2C, 1978.
43 Fed. Reg. 59451 (1978).
For the reasons set fcrth below, the request is denied.
The asserted basis for the NAEC's request is as follows:
(i)
By August 1977, the average settlement beneath the North Anna ptmpheuse for -Units 1 and 2 had reached 75% of its allcwable limit according to measurements made by Stone & Webster Company; 4 ()l
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(2) VEPC0 did not report this condition until April 28, 1978, more than 60 days after the report was required under the technical specifications; and (3) License revocation is an appropriate sanction in this instance because pres
's civil penalties for false or omitted reporting have been ineffective enforcement actions and failure to report constitutes a material false statement for which a license may be revoked.
Under Technical Specification 3.7.12.1 VEPC0 is required to submit a special report to the Commission within 60 days when er the total settlement of any structure or the differential se'!1ement c v structures exceeds 75% of the allowable settlement value for Class I structures.1! The Service Water Pump 1/ The NAEC also alleges that the settlement measured by Stone & Webster
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in August 1977 should have been reported in accordance with 10 CFR 50.55(e),
which requires reporting of certain deficiencies found in design and construction.
However, VEPC0 reported the problem of continuous settle-ment of the Service Water Pump House in 1975.
The Staff was aware of the continuous settlement problem, and noted it in its Safety Evaluation Report.
Stone & Webster's August, 1977 data revealed no new design or construction deficiency causec by settlement.
Moreover, the figure of 75% of allcwable settlement has relevance only to the reporting requirements of the technical specification, which did not become effective until November 25, 1977.
Thus, VEPCO was not required under 10 CFR 50.55(e) to make an additional recort of the Stone & Webster data.
3 House is a Class I structure.
Technical Specification a.7.12.1 further required that settlement "shall be detercined to the nearest 0.01 foot by measurement and calculation at least once per 6 months."
VEDC0 was bound to comply with the technical specifications upon issuance of the operating licenses for the North Anna Units on November 26, 1977.
Since the technical specifications became effective, VEPCD has retained Moore, Hardee & Carrouth Associates (MH&C) to perform the settlement survey in order to comply with the survey and reporting requirements of the specifications.
MH&C had been surveying settlement for VEPCO since November 1975.
Surveys performed by MH&C on various dates showed the follow-:ng measurements of settlement at the pump house:2/
Percent of Allowable Average Settlement Date Settlement (Feet)
(0.15 Feet) 12/1/75 0.000 0
7/11/77 0.063 42 12/12/77 0.103 69 3/15/78 0.121 81 3/30/78 0.119 79 4/25/78 0.106 71 5/10/78 0.110 73 8/3/78 0.117 78 11/06/78 0.126 84 11/20/78 0.124 83 1/03/79 0.128 85 2/06/79 0.127 84 3/07/79 0.126 84
~2/ Measurements taken between November 1975 and July 1977, prior to the effectiveness cf tne technical speci fications, do not show settle-ment in excess of 75% of allowable value under the currently applicable stardard.
4 The data indicate that 75% of the maximum allowable average pumphouse settlement was exceeded on March 15 and March 30, 1978.
Based on this information, VEPCO reported to the NRC on April 28, 1978, that settlement of the pumphouse exceeded 75% of the allowable value.
Although the NAEC does not dispute that VEPC0 reported settlement conditions to the NRC or, April 28, 1978, the NAEC contends that VEPCO should have made a report to the NRC within 60 days after the measurements of settlement made by Stone s Webster on approximately 4.ugust 3,1977.
As earlia. noted, however, the tech 7ical specifications did not con-into effect ur.il November 26, 1977 when the operating licenses were issued.
Thus, VEPC0 had no obligation under the technical specification to report data measured prior to its effective da te.
Even if the technical specifications were in effect in August 1977, Stone & Webster's measurements were not calculated with the precision required by Technical Specification 4. 7.12.1.
The technical specifications, in estab-lishing a requirement for a settlement survey program, required measurements of a certain frequency and accuracy. i.e., measured at least every six months by precise leveling, with second order Cla:s 2 accuracy as defined by the U.
- 5. Department of Commerce, National Oceanic and Atomospheric Administration, National Ocean Survey and calculated to the nearest 0.01 foot.
This specified accuracy exceeded that which Stone & Webster could assure with its ecuipment and techniques.
On the other hand, the surveys by MH&C, tne firm retained by VEPCO to perform the surveys required by the technical specifications, did meet the specif ied accuracy required by Technical Specification 4.7.12.1.
The surveys performed by MH&C exceeded the required frequency.
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5 As part of our review of the NAEC request, the NRC conducted an inspection on December 6-8, 1978, and an inspection / inquiry on March 5-15, 1970 of data collected on settlement of the pumphouse.- (See Inspectica Report No.
50-338/78-44 and 50-338/79-13 which are made part of this decision and attached as Appendix A and B.) The inspection findings confirm the accuracy of the MH&C data for purposes of compliance with the requirements of the technical specifications.
The inspectors found that the Stone & Webster data generally indicated approximately 0.01 foot more settlement than the MH&C data.
Moreover, the inspectors concluded that the accuracy of the Stone &
Webster surveys was questionable and that some average settlements computed by Stone & Webster were based on incomplete data.
In cases of conflict between the MH&C data and the Stone & Webster data, the inspectors deter:nined that the MH&C measurements should be accepted as correct because the MH&C survey was more carefully controlled and more accurate than the Stone & Webster sunei.
It should be emphasized that the two surveys served diffemnt purposes. The Stone & Webster survey was not performed to meet specific requirements of the PSAR, FSAR or the technical specifications, but was perfor:ned in accordance with standard engin2ering practice to confirm design assu::mtions and monitor
/ The inspection team also reviewed the cata anc inspected the expansion 1
joints for differential srttlemens between the pump house and the north side service water piping expansion joint.
The inspectors found that the data indicated insignificant differentici settlement and detected no problems in the expansion joints.
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6 settlement during construction.
By comparison, the MH&C survey assures compliance with Technical Specification 3.7.12.1 within the accuracy required by Technical Specification 4.7.12.1.
Accordingly, MH&C mada the required surveys for VEPCO within the specified frequency and VEPC0 reported within 60 days the measurements exceeding 75% of allowable settlement when indicated by the MH&C survey.
Although the Stone & Webster data may have indicated settlement of the pump house earlier than the data of MH&C, the Technical Specifications require the licensee to report settlement exceeding 75% of the allowed value only when settlement is measured in a survey of a certain accuracy after the technical specification's effective date.
Unlike the Stone & Webster survey, the MH&C survey met the accuracy required by the specifications.
Relying on the results of the MH&C survey, VEPC0 appropriately reported settlement to the NRC after receiving measurements taken by MH&C in March 1978.
VEPCO was not required to report the results of the Stone & Webster surveys.4/ Therefore, I conclude that:
3/ The NAEC misplaces reliance on a report dated July 19, 1978, Paul Rizzo to tne Advisory Committee on Reactor Safeguards in which Mr. Rizzo reviewed VE?CO's special report of May 31, 1978.
Upon review of the data contained in Figure 4C of the VEPCO report, which shows settlement measurements by Stone & Webster and MH&C between June 1977 and May 1978, Mr. Rizzo ccmmented that 75% of allowable settlement " occurred, fo-all practical purposes, as ea-ly as August 1977. " This is not to say, hcwever, that VEPCO was obligated under tne technical specification to report the Stone & Webster data or that tr,e MP&C survey made to comply with the technical specification indicated 75% of allowable settlement in August 1977.
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1)
The survey performed te meet the requirements of Technical Specification 3.7.12.1 indicated that the average pumphouse settlement exceeded 75% of the allowable value in March 1978; 2)
The surveys were made at the frequency required in the technical specification; and 3)
The licensee notified the NRC within 60 days of the time
,the survey detected settlement of 75% of the allowable valwe.
As VEPCO was in compliance with the technical specifications and 10 CFR 50.55(e), no enforcement action is appropriate, and accordingly, the NAEC's request to revoke the North Anna operating licenses is denied.
It is therefore unnecnssary in this context to reach the question of a material false statement.
A copy of this determination will be placed in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C.
20555, and the local Puclic Document Rooms for the North Anna Power Station located at the Louisa County Courthouse, Louisa, Virginia 23092, and the University of Virginia, Alderman Library, Charlottesville, Virginia 22901.
A copy of this document will also be filed with the Secretary of the Commission for its review in accordance witn 10 CFR 2.206(c) of the Co,nmission's regulations.
46i
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8 In accordance with 10 CFR 2.206(c) of the Commission's Rules of Practice, this decision will constitute the final action of the Commission twenty (20) days after the date of issuance, unless the Commission on its own motion institutes review of this decision within that time.
M 4%6V%o,h Victor Stell J r.
Director Office of Inspection and Enforcement
Enclosures:
Appendix A:
(IE Inspection Report No. 50-338/78-44)
Apendix B:
(IE Inspection Report No. 50-338/79-13)
Dated at Bethesda, Maryland this 7;[ day of June 1979 S
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In Reply Refer To:
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RII:JC3 E-50-338/78-44 s-
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Virginia Electric and Power Cocpany
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i Senior Vice President, E.1 Power
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?. O. Box 26666 E.___
Richmond, Virginia 23261 g
Gentle e::
This re f e rs to the inspectica conducted by.Mr. J. C. B rya r.: of this I
office c: Dece=ber 6-8, 1978, of activities au.hcri:ed by NRC !. ice r Nc..WF-l. for the Ncrth A=.na Power Station, Iw I facility, and to _ e discussi;c cf cur findings held with Mr.
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A. Sla.e: at the cenclusien of the iLagectice.
Area s exa. ned during the inspectice and our findings a re discussed ir:
the e ci ose d inspection repert.
Within these areas, the inspectio cc:sisted c f se.1ective exa:ications of procedures and representat1ve reccrds, in:erviews
-i-h perscenel, and obsersa.icas by the inspecters.
Withi: the scope of this ins,cectic, cc iters of :::ce:pliance were disclosed.
We have ex.=ined actic:s vou have taken with regard
.c previcu:1y repe r.ed resolved ite=s.
The status of these ite s is discussed in
-he enclosed report.
In accercance with Sectie: 2.790 of the NRC's " Rules cf ?ractice",
Par. 2, Title 10, Ccde cf Federal Regulaticas, a cep. cf :.his letter and the e: closed inspection report will be placed in.he NRC's Public Docu=en: Roc =.
If this report co.ains any infor:a. ion that you (or
- v. eur contrac:cr) believe to be prc:rietarv,, it is necessarv. that v. o u
= a r.: a wri.te applica-icn within 20 days te this efiice te withheld such inic-atic: frc: public disclosure.
Any such application =us.
i:c'_ude a full s:a.ecent of the reascas c= the bas:s cf which i; is
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clained that the information is proprietary, and should be prepared so
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If we do not hear frem vou in
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yhou d you have any cuestions conceming this letter, we vill be glad o c.scuss them with you.
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Sincerely,
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James P. C':eilly 1.
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Report No. :
50-338/78-44 Docket No.:
50-338 License No.:
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B2 I.icens e e :
Virginia Electric and ?cver Cec:pany Post Office 3ex 26666
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Richec:d, Virginia 23261 r a ct.3 :. e N.a=e:
No rth.c.a tower Sta tic. y=it 1 I:spectier at:
North A::a ?over Statica, "ineral, Virginia I: spec.ic: cc: ducted:
Eece:be r 6-E, 1978
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LET.1.IES. I Prepared by:
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J. J g Lenahan, Civil Engineer Date un Engineering Supper: Sectica No. 1 1_..
Reac;cr Constructic: and Engineering
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Su pert Branch 1__
r Dates of Inspectic :
Dece=ber 6-8,'1978
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Reviewed by:2 M.
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J. C. Bryant, Chief f
Late Engineering Support Sectie: No. 2 Reac;cr Constructica and Engineering
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Supper Sranch
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Virginia Electric and Ocuer Cc=pany (VEPCO)
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Schult:, Superviser,
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- T= R. C. Sturgill, Assistant ingineer, Unit 1 E. R. 3ane, Superviser, C :structie: QA
- P. A.
Slater, Reside:- QA Engineer 7_ _ g 4. e _ - 4 g _.-". 4.
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? Diehl, Engineer, Engineering Services
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Settle =ent of Class I Structurc s.
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settlecent data.
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Utresolved Ite=s No new unresolved ite=s were identified during this inspection.
4.
Indecencent Inscection Effort
'!hera was co independent inspectio:: conducted during.his inspection.
5.
Scope of Soecial Insoection On April 28, 1975, the licensee notified RII that s u rv e v, readi=gs r
taken on March 30, 1978, indicated that the average settleme. of the (S.,-..)
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RII Ept. No. 50-338/78-44 I-4 m.
exanined the settle =ent points in the service water pump house (SWH) and en the north side of the expansien joint in the senice
~1 vater lines, and benchnarks (Reference " :ucents A and 3) used in the settle:ent survey.
Reference Monuments A and 3 consist of
=
s. eel casi:g drilled and greuted into rock.
Se. lement points in the SW" are brass =arkers grouted into the concrete ficor.
=__
Settlement points ca the service water lines are painted on the i=-
nin. e s.
=...
The procedure used by.MC in the settle en su vey fcr the SWH is to run a level line fren Reference Menument A along the dike c' *he se..'c-va*...-
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c that recuired f:r secc:d crder Class 2.
Su-veys are beine f
O
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u SC survey da:a i:dicated the fc11cving average se-vice water
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Date Average Se::lenen: (Feet)
(0.15 Feet) 12/1/75
.000 0
7/11/77
.063 42
/3.2/.,
. 103
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RII'Ept. No. 50-338/78-44 1-5 p._
1978, indicated settle =ent was less tha 75%.
Based on the above
[T da ta, the licensee sent a Licensee Event Re"eort to NRC on April 28,
'~ ~ '
1978, that Sk?H settle =ent exceeded 75% of the allowable value.
1 May 31, 1978.
]_
A detailed special report was sub=itted to NRC c:
b.
Construction Se tlement Survey Progra= - Settle =ent of the Sk?E
[
ale:g with other structures was =ocitored by Ste:se and Webster.
i-during constructic=.
This was not a requirement of the PSAR, FSAR, or :.he Technical Specifications but was do::e in accordance w :.. u s'.andard engineering practice to ces,.ir: cesig assu_ptions.
The.equire=ents of the S&W settle =ect surveilla:2ce program were
==
de'.er=ined by their Geotechnical Engiceerr.
This program was =ct a rigid project requirement, and at times surveys were act =ade due to higher pricrity work.
However, the f requency of the constructica survey progra: was adequa te to ebtai= a good se:.le-ment histerf of Sk?H.
Fre: the results of the S&W surveys, the licensee dete =ined 3:d reperted to NRC in April 1975 that the Sk?H se.tle=ent exceeded the PSAR esti=ar.es.
Additic:al design studies were ade by S&W to investigate settle =e
- cf the Sk?H and de:.e. ine stresses in the ser rice va.er lines at their cennectiets
- .o the Sk?H.
As a result of these studies, S&k est.i=ated that Octal average addi-tic:al settle:ent of the Sk?H wculd be approxi=a _ely 0.15 feet af:er Dece:ber 1975 and flexible couplings v -- : stallec in the service water lines at their con.nectice to the SWH.
The inspec:crs reviewed the survey field book i:t ubich the S&..
Sk?H s e tt.le=ect suriey data was recorded and discussed survey technicues with S&k engineers.
S&W surieys were =ade f rc= a variety c f benchma rks, including Refere:ce Mccu=ents A a:d 3, and s everal :.e:pe ra ry ccestruction benchma rks.
S&W engi:eers star.ed tha: the precedure they used ce their settleme :. survey was ;c run a level line f rc= o=e o f the bench =a rks
.o
.he Sk?H, es tablish a T3M i: the.icinity c f :.he Sb?H, and close the loop by either tying back into the c.iginating benchmark er one of the ether benci= arks c: the p roj e c t..
Ecwever, t.he survey loop closure was ec docu=ented in the field book for each S&k se t t l e=e s t suriey.
Locp closures docu=ented i: the field book were closed wit. hic a ccep able a ccura cy.
The rods used in the Sak survey did cct teet the recuire=e::s ef the ty e specified by NCAA fer use ir secend order, Class 2 differential leveling.
There was se=e discussic that one of the S&k rods might have been slightly da:ared.
The S&k engi:eer esti=ated er crs of ut. :
.C'.
feet.
S&k su-vev. ca:a was inec=:lete fer read:rgs cade frc: A gust 3, 19 7 7, thr ;u gh Janua rf 5, 1975, 9 p: t.4n.- m.re.q t e -)
Pe O
t 5,: r t,: p ;,
g;s c
c.
?
b Le I
g s a
.(
.=
m FJ: ?.pt. No. 50-338/75-44 I-6 x,__
because settle:ent point SM-8 was inaccessible to S&W surveyors though MH&C surveyors did record data for this point in Dece=ber,
"~
19st.
ihe cissing data for pein: SM-S can be interpolated frcm the other data to the neares
.01 foot.
~~
In co=parison of MH&C data with S&W data, the inspectors noted h
that S&W data consistently indicated approximately.01 feet more se :lecent than the MM&C data.
From exa=ination of the field data and the discussicas with S&k engineers, the inspectors cc:cluded that the S&W survey uld co: =eet the recuire:ents of a seccad order, Class 2 survey, and that the SWPH settlements shown for the period frc= August 3,1977, through Januar.- 5,1978 vere based on seo:plete data.
The survey =ade for purposes of =eeting the recaire:ents cf the Technical Specifica:ic:s va tha: cade by MH&:.
In cases of conflict between the MH&C data and the S&W da a, the MH&C data veuld be accepted as correct since it was cbrained fro = a survey which was better co rolled and =cre accurate -ha: - h e S &'-
s u rv e y,
c.
Differential Settlene:: 3etvet: SVpH ::d North Side of Service e
_.::e : spectors reviewed the results Water r:p:rg xp2:s :: soin of surveys perferred by MM&C to ceasure settle ent of the service water lines certh cf the expansic: joints.
Cettle=e:: ef the service water lines was cc pared to -he settle:ent cf SW?H se: le-
=en pein: SM-7, which is located on the certheast corner of S '-?F..
This is the locatic: where the service water lines enter the pu=pheus e.
The settle e:- of pei:: SM-7 versus the se::~ ement of the service water lines is tabulated be ov.
Differe ial Se :.:e=en Differential ee: vee:
3etween ce
-.-7 cw
-..-15
(" i e c w '...
c..u. 'a^
cu c_,v. - 1 e-("
~
-..,a
-,l..,,
.0uc
.000
.000 if u 12/12/77
.039
.051
.012
.C53
.019
..f,1, / / e o--ce O '/ A
.0
. 0 v '1 0
^-*
.ygg
/30/75
.057
.072
.015
.077
.020 s.
-/~af/
. u, - c
.Le0
. 0,. 0
. 0 c..c
.021 3/10/7S
.043
.064
.021
.071
.02S 3/3/78
.055 066
.005
.069
.011 NOTIS:
(1)
July 11, 1977 is. date whec initial survey was perfer:ed
~
c: service water lines.
(2)
SM-15 is settle =e::,tcia: c: e a s ; n. ic. e.
(3:
SM-15 settle ent pci:
ce ves pipe.
- s. y e s j
- h.
r p q.
4 Sh F-S
/
4
- - q rJ i JUU
-=-
i.=.;. -
RII. ?.p t. No. 50-338/78-44 Ii c
=.-
=. '. _
(4)
Co=plete MH&C data not tabulated in above table.
Z
=-
(5)
Settle =ents shown are in feet.
=
--E =
==s The above data indicate that differential settle =ents between the
- -sE service water lines north of the expansion joint and the northeas n_
corner of the Sk7H has been insignificant since July 1977.
The i=5=
data also indicate that the service water lines have settled mere
=
than the Sk?E.
The expansion joints in the service water lines are
= :-
located where the height of fill in the dike is th greatest.
]
,he expansic: joints in the service water 1:..nes were 1:sallec. :.:
4 March 1976.
An estimate of hcw =uch the serrice water lines have
~~
settled si:ce the expansic jci :s were installed can be ade by co:carison of Sk?H settle ent data with the available service water line settle =ent data.
Settlement point SM-7 settled.0!.6 fee. betwee: Dece:ber 1975 and July 19ei.
2his is approxicately
- e sa.:e ca ::..ude Sy. settled.se: ween Julv.
l.., e anc av. 19.tc y
i 5
when the largest differential se le:en: between the service vater lines and the point SM-7 is indicated.
Therefore it is cc:ceivable that an ecual a=ount of dif f erential se::le=ect b e twe e: SM-7 a:d the service water lines occured between March 1976 and Jul. 1977 as occured betwee: July 1977 a=d May 1975.
This would =ea: ::a* a =ax u: of apprcxicately cre-half inch cf dif ferential settle =en. cay have occured between the Sk?E and the service water lines since.he ex:ansic: jci:ts were installed in March, 1976.
The expansic: joints are designed to tolerate up ::
three inches cf dif ferential settle =ent between the Sk?H and the service water lines.
The inspec:crs exa:ined the expansic:
.i, c i:.s du ri:6-the inspectics and detected to prcble=s.
d.
Conclusicas Based on the results of exa=i:ation of se:-le=ent data sad su: eey precedures and discussiccs wi;h respensible engineers 7.he inspec crs concluded:
The su-vey performed to =ee the re;. ire =e=ts of Technical a.
Specification 3.7.12.1 indicated t. hat.he average pu phouse se:.lemen exceeded 75% cf the =aximum alicwable value i:
Z
- u. a. _ u.,, c.. e.
b.
Se. lace:* surveys are being Cade a: the frecue:cy recuired e
..a A. w,e_,-
w g, e - 4 :s.4.
a s ' w.. h.
c s
s s.s.
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s c
UbUh
'd u i s @ 0 4 t.. &s 461
~3 U I
.e.
-s
- =--
KII'St. No. 50-338/78-44 I-8
-r
- .=:.:
c.
The licensee notified N?,C within 60 days (time period specified J.1E. _ _
in the Techrical Specifications) of when 75% of the allowable 3.iE.~
settle =ent of the Sk?H was detected.
d.
The a=ount of differential settle =ent occurring between the Sk'?H and the service water lines is well within toleranc-No deviations or itens of nonce =pliance were identified.
555
=::
'7.
Exit Interview
. -. =.
The inspectors =et with the licensee representatives denoted in paragra-h 1 r
on Dece='oer 7, 1978 and on Dece=ber 8,1973 to discuss the results of the nspection.
The inspectors su::arized the scope and findings of
=='
their exa=ica:ica of data collected on settle =e -
4-
%'?H a nd o f
"=
=
actica on previoits inspection findings concerning settlement survevs.
No deviations or items of concc=pliance v n-identified.
e e
e
+ -. - +
..m fh d;a
,1 - 2 !.1;i; l 0;h p.)UILL.
. a. s a d J u i =
J'
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\\.
UNITED STATES \\
R ao g,q*
NUCLEAR REGULATORY COMMtsSION o*.
REoloN 11 n
k 101 M ARIETTA STREET,N.W.
- y An. ANT A. oEoRotA 3c3o3
, gh-f Xs f APR 2 51979
%,.+
In Reply Refer Jo:
RII:JJL 50-338/79-13 i
Virginia Electric and Power Company ATI'N:
W. L. Proffitt Senior Vice President, Power P. O. Box 26666 Richmond, VA 23261 Gentle =en:
This refers to the inspection conducted by J. J. Lenahan of this office on March 5-15, 1979, of activities authorized by NRC License No. N??-4 for the North Anna Power Station, Unit I facility, and to the discussion of our findings held with W. R. Cartwright at the conclusic of the inspection.
Areas exa=ined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective exa=inations of procedures and represen.ative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, no ite=s of nonco=pliance were disclosed.
We have exa=ined actions you have taken with regard to previously reported unresolved itens.
The status of these ite=s is discussed in the enclosed report.
One new unresolved ite: resulted f cm this inspection and is discussed in the enclosed report. This itec vill be exanined during subsequent inspections.
In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulaticas, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Doc.=nent Rece.
If this report contains any infor=ation that you (or your contractor) believe to be,
proprieta ry, it is necessary that you =ake a written application within 20 days to this office to withhold sucn infor=ation frc:n public disclosure.
Any such application nust include a full' statement of the reasons on the basis of which it is clai=ed that the infornation is proprietary, and should be prepared so that proprietary infor=ation identified in the application is contained in a separate part of the docu=ent. If we do not hear from you in this regard within the specified period, the report vill be placed in the Public Document Roo=.
A6-
~}
DefP 7' PlD R 0 bb$'b[ibN'"
Appendix B 3o 3 -.
p
..s Virginia Electric and Power Co. Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, e
fcr9_r_.0_6_-
m es P. O'Reilly D1 ector Enclesure:
N Inspection Report
.o.
50-33S/79-13 cc v/ encl:
W. R. Cartwright, Station Manager Box 402 Mineral, VA 23117
?. G. ?c::7 Senior Resident Engineer P. O. Ecx 38 Mineral, VA 23117
?
4 304 3
Jr (3,
wa..
(
g uag#c, NUCLEAR REGULATORY COMMISSION p
J' REGloN 11
^
n r
~
.j 101 MARIETTA STREET.N.W.
" y %,n' ATLANTA. GEORGIA 3:3c3
$es.W*.*;!
i Report No. 50-338/79-13 Licensee:
Virginia Electric and Power Co=pany Post Office Box 26666 Rich =ond, Virginia 23261 Facility Name: North Anna Power Station, Unit 1 Dochet No. 50-338 License No. NPF-4
' Inspection at North Anna Site near Mineral, Virginia, VEPCO offices, Richmond, Virginia, and Stone and Webster E gineering Corporation (3&W) offices, Soston, Massachusetts Inspector:
[E.
F,<-/p f J. @ @e ahan Dan' Signed Acco=panying Personnel:
C. E. Aldersen Approved by:
dh&M d"'/'pr
/~
J CT E6 art, Section Chici, RCES Branen Date Signeo f
SL 21ARY Inspection on March 5, 6, 14 and 15, 1979, at North Anna site; March 7,1979 at Richcond, Virginia; March 13, 1979 at 3oston, Massachusetts Areas 1:svected This special, unan:cunced i=. -etion involved 21 inspector-hours c -site and 18 inspector-heurs in the VEi and S : e and Vebster Corporate Of fices in the areas of settlement data collected on Units 1 and 2 service water pu=phouse, perfor:ance of horizontal drains, collectica of piezo=eter data and licensee action en previously identified ite=s cencerning settle =ent surveys.
In addition, an inqui:f was conducted concerning hsndling and review of service water p =phouse settle =ent data.
The inqui:; involved 11 hcurs on-site and 18 hcurs in the 'F.FCC and Ste:e and Vebster corporate effices by an NRC investigater, The S-ary of Inquiry is appended to this inspectica report.
Results Of the areas inspected, no apparent ite=s of conce=pliance or deviatices were identified.
- n\\ r_)
R I 1
'\\
L) Q \\
JU g gajo3
DETAILS 1.
_ Persons Contacted i
--Licensee E=cloveer C. M. Robinson, Supervisor, Civil T.agineering Services
- 0. Schults, Jupervisor, Survey Services
'C.
E. Sorrell, Civil Engineer
- J. V. Waddel, Manager, Power Station Engineering P. A. Slater, Resident QA Engineer
- E. R. Smith, Jr., Supervisor, Techni Services
- J. D. Kella=s, Ruperintendent Statio: c'erations
- V.
R. Cartwright, Static: Eanager R. C. Sturgill,4.esistant Engineer T. Schreckengb t, Engineering Technician Other Orzaci:=tions D. Earry, Resident Engineer, North Anna Site (S&'J)
B. McIver, Geotechnical Engineer, Boston (S&W)
NRC Resident Insoector
- M. S. Kidd
- Attended exit interview.
2.
Exit Interview The inspection secpe and findings were su==arized on March 15, 1979 with those persons indicated in Paragraph 1 above.
3.
Licensee Actic: c: ?revious Insrectie Findings (Open) Unresolved Ite: (33E/7S-37-04): Settlement of Class I Structures, Technical Specifications are not clear c= settlement survey requirements for reset survey points and baseline dates since several of the points were not required by NRC until af ter the baseline dates had passed.
Also, though some of the points were in existence prior to the a ep ro-priate baseline dates, survey reading: were act cade en the baseline date.
A typical example of this is pc'
---ber 117 en the service building.
The Technical S,6ecificatices specify a li=it en the settle =ent cccurring a f ter April 1,1977.
Ecwever, settle =ent surveys vere =ade March 9,1977, and not en April 1.
Therefore, it is necessary ::
c:
extrapelate the post April 1 settle =ect f or Point 117.
Other exa=ples of the =ecc to clarify baseline dates are settlement points 206 through il
/
_46I M,
=9
x
. 209 on the Boron Recovery Tank Dike.
The technical specifications specify limits en settle =e.nt af ter co=pletion of construction (i.e.,
"as built" sett'.c=ent).
However, these settle =ent li=its were not required by NRC and initial settle =ent readings were not made until May 1976, = ore than one year af ter this structure was built.
Six points have been reset since the technical specification baseline date. This was due either to construction activities which resulted in points being destroyed or erection of per=anent facilities which have
=ade points inaccessible to surveying.
However, the licensee has a large redc=dancy in survey =enitoring points and, therefore, was able to reconstruct the settle =ent history of reset points frem other settle =ent points on the sa=e.tructure or fro = sett' e=ent points on adjacent structures which have similar foundation anc loading conditions.
A typical exa=ple of how =issing esta were reconstructed for reset points can be illustrated for point nu=ber 144 on Unit I contain=ent structure.
In addition to point nu=ber 144, the licensee had estab-lished 5 other points, numbers 126, 127, 130, 143 and 149 on the Unit I contai =ent structure.
These additic al points were surveyed at the sa=e frequency as point nu=ber 144.
poi
-"-ber 144 was destroyed between the 10/8/76 and 7/7/77 readings; however, it is possible to reccastruct the =issing data for point number 144 fro = data ecllected for the other pcists.
The readings collected for the other 5 points on the structure indicated an everage of app:cxi=ately 0.016 feet of rebound during the period 10/8/75 through 7/7/77.
Since all the points are on the same rigid s tructurt, it is reasonable to conclude that point =c=ber 144 also rebounded 0.016 feet during this period.
point nu=ber 144 indicated 0.003 feet of se.tle=ent betwee 5/13/76 and 10/S/76 and 0.005 feet of settle =ent between.7/7/77 and 10/25/7S.
Therefore, the net apparent
=cve=ent cf point number 144 since May 1976 is actually.008 feet of rebound, not settle =ent.
The Unit I contai =ect structure is founded en rock.
The inspector concluded, based en the data, that the struc-ture =cs: likely has no =oved since Y.ay 1976, and the s=all apparent
=ove=ents are a result of the li=its of accuracy of surveying.
The inspector exa=ined installatice of two additional per=anent bench = arks which had been established in the main plant area.
These bench = arks had been drilled and greuted into rock.
Although the surveys =ade to date =eet the require =e=ts for U. S.' Depart = cut of Cc=merce, National Oceanic and At=cspheric Ad=inistration (NCAA) Seccad Order, Class II accuracy, the survey results will be i= proved when these bench = arks are used since they are =uch closer to the pla:t than the bench = arks presently in use.
According to NCAA standards, accurary in leveling is a function of the square root of the distance surveyed.
A reductica in the distance aet 7r7 4Oi Id/
s suneyed will lower the acceptaole errors of aosure, thus increasing survey accuracy.
Also, a reduction in distance surveyed vill nduce the nu=ber of turning points, which will add to increased ~ survey accuracy.
~
The inspector ers=ined the licensee's revised procedure to be furr.ished to Moore, Eardee, and Carrouth Associates (MH&C), the engineeri:- firm retained by the licensee to perfor= the settle =ent surveys. This procedure lists requirements for collection and reduction of survey data, transmittal of th-data to the licensee, and QC require =enta.
The ti=e lzpse between co=pletion of the S&C surveys and evaluation of the data by the licensee was up to four =enths in the past.
This revised procedure requires S&O to trars=it survey data to the licensee within seven working days af:.er ce=pletic: of the surver.
~~he inspecter discussed with licensee =anagement the need to protect settle =ent points frem being disturbed by construction and other cetivities.
The licensee is still evaluating =ethods to be used to a ece=plish this.
Band on review of the settlement data collected to date, it appears that the licensee har cet the intent of Technical Spe::ficatica 3.7.12.1, i.e., to monitor and evaluate settle =ent of Class I st=uctures.
The licensee has request..d a change to the Technical Specification to clarify baseline dates and reset survey peirts.
Unresolved ite=
338/78-37-04 re=ains open pending revisic: of the Technical Specifi-cation and NRC review of :he licensee's corrective action and final report.
4.
Unresol.ed Items Unresolved ite=s are =atters aboct which : ore infer =ation is required to dete =ine whether they are acceptable or =ay involve conce=pliance or deviations.
New unresolval ite=s identified during this inspectice are discussed in Paragr,ph 7.e.
5.
Inde endent I:soection Effort The inspecter exa= iced the service water reservoir e=back=ent, including slepe protectics, slope stability, a d downstrea= e= bank =ent toe.
No deviatices er ite=s cf necce=plia=ce were identified.
6.
Sc ee of Ceecial Inscecti g C: April 2S,1973, the licensee notified NRC Regien II that survey.
eadings taken by S C c:. March 30, 1973, indicated that the. average settle:ent of the senice water ;u=p bcuse (SVFE) exceeded the value 461 300 required for reporting, i.e., 75". of he maxi =u:2 allowable value of 0.15 feet. The licensee submitted a special written report regarding the S~@H settlement to NRC Region II on May 31, 1978.
This special i
inspection was perfor=ed to:
Make a cocparison of the Sk?H settlement dats collected by Stone &
a.
Webster (S&W) with that collected by Moore, Hardee and Carrouth Associates (MH&C).
b.
Evaluate MH&C Sk?H settlement data collected since Nove=ber 1978.
Evaluate differential settlement data between the Sk?H and the c.
north side of the service water piping expa=sion joints, and visually exa=ine the expansion joints.
d.
Deter =ine the perfor=ence of the herinental drains.
/
~
Revi-v pie:ometer da =
e.
In addition, an inquir, was conc:teted during the inspection by a Regional Investigator concerring the licen ee's handling and review of Sk?H settle =ent data.
The Su==ary of I%
.f
__ appe=ded to this inspectien report.
7.
Findings Cocparison or S&W and MH&C SkTH Settlement Oata - S&W, the plant a.
designer and constructor, =cnitored settlement of the Sk'd5 during it.s constru:.: tion in accordance with standard engineering practice to conf c.a their design assu=ptions.
MH&C uns retained by the licensee to perfor= the surveys required by the Technical Specification 3.7.12.1.
The inspectoE exa=ined the S&W survey field book containing the Sk?H data collected by S&W surveyors, reviewed calculations reducing the raw field data collected by S&W and MH&C to the cc=puted S*aH settlement, =ade an independent check of these calculations, and co= pared the SWPH settlement. calculated frem the S&W field data to the settle =ent calculated frc= the MH&C data.
A co=parison of MH&C and S&W settlement =easuremen'.s is shown in the f ollowing table:
~
. (j i JL/
(
t
. MH&C DATA S&W DATA Average SWFH Average SWPH Date Settle =ent(ft.)
.Date S e ttle=ent (ft.)
i 12/01/75 0.000 12/10/75 0.000 12/17/75 0.001 12/19/75 0.000
~
8/23/76 0.011 8/21/76 0.020 10/01/76 0.022 10/07/76 0.029 10/06/76 0.027 11/10/76 0.033 11/13/76 0.039 12/01/76 0.038 12/06/76 0.031 12/15/76 0.064 2/24/77 0.061 3/03/77 0.061 3/2S/77 0.068 5/23/77 0.066 7/11/77 0.063 8/03/77 0.114 8/29/77 0.112 10/06/77 0.114 10/31/77 0.113 12/12/77 0.103 12/08/77 0.117 1/05/78 0.116 3/15/78 0.121 3/01/78 0.112 3/30/78 0.119 3/29/78 0.123
- / 25 /78 0.107 4/20/78 0.118 5/10/78 0.110 5/12/78 0.132 Fotes (1)
Settle =ent shove is in feet (2)
S&W settlement values for S/3/77 through 1/5/78 are based on inco=plete data; 1.e., no readings were made on settle =ent point SM-8 during this period.
Missing data for SM-8 was interpolated frc= other data.
The Technical Specifications require that the licensee perfor= an engineering evaluation to deter =ine the consequences of additional settle =ent when the average settle =ent of the SWPH e :eeds 75% of 0.15 feet (0.1115 feet).
The licensee is required to notify the Co==ission and sub=it a special report within 60 days of when this li=it is detected.
S&W data indicate that 76% of the allowable SW?H settle =ent of 0.15 feet occur d by August 3,1977.
- However, the MH&C data ndicates only 42% of the allowable s --'---, had occurred by July 11, 1977, and that 69% had occurred by De c =ber 12, 1977.
S&W data of ece=ber 8, 1977 indicates, for all prat _ical purposes, no change fro = the Augus 3 data.
The difference, 691
-f3
( ;D lj Q i Jl d
s
. MH&C data did of 0.15 and 76% of 0.15, is less than 0.01 foot.
not indicate that the allowable settlement (75% of 0.15 f t.) was exceeded until March 15, 1978.
9 The S&W data generally indicated approximately 0.01 foot more Examination of the data in the S&W settlement than EH&C data.
survey field book disclosed that survey loop closures were not documented for the period between March 28, 1977 and March 27, Since these loop closures are not docu=ented, the accuracy 1978.
In addition, of the S&W surveys for this period is questionable.
S&W did not make settlement survey readings on settlement point SM-S (S&W point number 3) f rom August 3,1977 through January 5, The settlement data for point SM-8 was interpolated from 1978.
the data obtained for point nu=bers SM-7, SM-9 and SM-10.
Therefore, some of the S&W average se.tlements shown in the above ed on suspect and/or ince=plete surevey data aad in table are ha any case would not have the sa=e degree of a.ccuracy as the MB&C data.
The MH&C average SWPH settle =ent shown in the above table is based on ce=plete data obtained from well controlled curveys which vere made to Second Order, Class II accuracy.
The MH&C survey loops In cases of were closed with acceptable accuracy in all cases.
conflict between the MH&C data and the S&W data, the inspector concluded that MH&C data would be accepted as correct since it was cc=plete and was obtained from a = ore accurate and better con-trolled survey than the S&W surveys.
A more detailed discussion concerning MH&C and S&W survey procedures is contained in Region II inspectica report number 50-338/78-44.
No deviations or ite=s of nonce =pliance were identified.
Evaluation of MH&C SW?H Dat: Collected Since Nove=ber 1977 - The b.
inspector reviewed MH&C SW?H data collected since November 1978.
Selected M3&C data is given below to show trends:
Average SW?E Percent -f Allowable Dace Settlement (Teet)
Se ttle=e nt (.15 Feet) 12/01/75 0.000 7/11/77 0.063 42 12/12/77 0.103 69 3/15/73 0.121 81 3/30/73 0.119 79 4/ 25 /7 3 0.106 71 5/10/73 0.110 73 S/03/73 0.117 78 I
/
g.,.,
\\
\\ ll
. Average SWPH Percent of Allowable Date Settle =ent (Feet)
Settlement (.15 Feet) 11/06/78 0.126 84 11/20/78 0.124 83 1/03/'i9 0.12S 85 2/06/79 0.127 84 3/07/79 0.126 84 Noted Dece=ber 1,1975 is the baseline date for.c'.PH settlement in the Technical Specifications.
The data for Spring and early Su==er 1978 indicate that average SW?H settle =ent was cpproximately 0.115 feet.
Readings made in Nove=ber 1978 through March 1979 indicate that average SWPH settle-
=ent was approxi=ately 0.125 feet.
This means that the SWPH settled an additional 0.01 foot between early Su=mer and early Winter 1978.
The licensee indicated that =onitoring of SW?H settlement will con-tinue on a conthly basis until further evaluation indicates the frequency can be reduced.
No deviations or ite=s of nonco:pliance were identified.
Differential Settlement between SW?H and North Side of Service c.
Water Piping Expansion Joints and Inspection of the Expansion Joints - The inspector reviewed the results of surveys perfor=ed by MH&C since Nove=ber 1978 to measure settlement of the service water lines north of the expansion joints.
Settlement of the. service water lines is co= pared to the settle =en; of SWPH settienent point SM-7, which is located en the northeast corner of the SW?H vhere the ser-vice water lines enter the pu=phouse.
The settle =ent of point SM-7 versus settle =ent of point nu=bers SM-15 and Sh-18 on the two outboard service water lines north of the expansion joints is tabulated below.
Data are selected to show trends.
Settle =ent in Feet Differential Differential Between Between Point Point SM-7 Foint SM-7 Date SM-7 SM-15 and Sh-15 SM-13 and SM-13
\\,/
't
.000 7/11/77
.000
.000 12/12/77
. 0' 9
.051
.012
.053
.019
.071
.012
.081
.022 3/15/73 0;) 3 t
li, I
ly D \\
bL
/9
-==g es
(
i
. Differential Differential Between Between Point Pof=t SM-7 Toint SM-7 Date SM-7_
SM-15 and SM-15 SM-18 and SM-18 3/30/73
.057
.072
.015
.077
.020
~
4/25/78
.045
.060
.015
.066
.021 5/10/78
.043
.063
.020
.071
.028 8/03/78
.051
.066
.015
.069
.018 11/06/78
.058
.081
.023
.082
.024 11/20/78
.057
.083
.026
.083
.026 1/03/79
.063
.095
.032
.090
.027 2/06/79
.061
.101
.040
.090
.029 3/06/79
.061
.097
.036
.08S
.027 Notes:
is date when initiM survey was performed (1) July 11, 1977 on se.wice water lines.
(2)
SM-15 is settle =ent point c east. pipe.
(3)
SM-1B settle =ent point on vest p:ipe.
The above data indicate that differential settlements between the service water lines north of the expansion joints and the northeast corner of the Sk?H has been approxinately 1/2-inch since July, The data indicate that the service water lines have settled 1977.
The expansion joints in the service water core than the Sk?H.
lines are located where the height of fill in the dike is the greatest.
Monitoring of pipe settlenent was not initdated until July 1977 while de expansion joints in the service water lines were installed However, conservative estimates of in August and October 1976.
the total differential settlement which has occurred between the can be made by S*=?H and the north side of the expansion joint comparison of Sk?H settlement data with available serrice water Settle ect point SM-7 on the Sk?H settled line settle =ent data.Dece:her,1975 and July,1977.
The =axinu=
0.046 feet betwee:
vice lines for differect'il settle =ent between SM-7 and the st occuring in this zag
.ude of settle =en; of SM-7 was 0.028 feet, Therefore it would be reasonable to conclude that the May, 197b.
of differential se: le=ent between SM-7 1:d the service a=ou :
water lines in the ti=e period August 1975 to July,1977 was This a=ount, added to i-inch approxi=ately 3/5-inch (0.03 fee.).
which has occurred since July 1977 would mean tha; approxinately 7/8-inch of dif ferential settle =ect has occurred between the 113
_ ig 1loi e
m OMMO k
9 (point S.M-7) and the ervice water lines since the expansionThe expansion joints were installed in August and October 1976. jo
~
The settle =ent between the Sk'?H and the service water lines.
inspector exa=ined the erpansion joints during the inspection and detected no problen.
No deviations or itens of nonce =pliance vere identified.
Perfor=ance of the Horizontal Drains - The licensee comitted in an a=end:ent to the FSAR to control the ground water level in the d.
The licensee had considered the use of deep vicinity of the SkTH.
wells, but this =ethod was ruled out af ter the results of pu= ping due to the icv per=cability of the insitu tests indicated that, soils, large dravdoves and close well spacing would be required.
The licensee then elected to use drilled he.-izontal drains.
Drilled horizontal drains to control groundui ter have been in use cu=erous proj ects, including da=s, highways,
since the 1940's c railroads, buildings, and other structures.
1976.
During The initial drain, drain 0 was installed in August, installation of this drain the i=per=eable liner of the reservoi-The licensee reported this to NRC Region II as a vas punctured.
After repairs to the liner vere co=pleted and 50.55(e) ite:.
installation procedures were revised, horizontal drain nu=ber 1 October,1976 as a test drain.
The was installed at North Anna i:
data gathered from this drain was used to deter =ine drain pipe Based on the size, drain spacing, and drain flow characteristics.
drain I, the licensee dete==ined that five data gathered fre:
additic a1 drains were needed to ec trol the groundvater level in the vicinity of the SW?H. The additicnal drains, drains 2 through The drains were 6, vere installed in July and August of 1977.
time of installed near the g-oundwater table elevation existing at
. stallatics.
The inspector exa=ined field books containing records of the hori: ental drain installation and discussed installation techniques Exa=ination of the records disclosed with the zespersible engineers.
that af ter the proble=s with drain 0 had been resolved, installation The location of
---aining drains was carefully controlled.
o'
- ka the drains, beth horizontal and vertical, was deter =ined during Drain 4 was i stallation using various types of ins - -- *atica.
installed at elevatica 272.5.
The re=aining drains were installed 276.
between elevation 274 and elevatic The inspector exa iced records of periodic tests perfor:ed by the licensee to measure the volume of fiev frc= the horizontal drains and to =casure the turbidity and suspended solids in the effluent frc= ;he horizon;al drains.
Records exacined were those of ;tsps 461
?> 14 M.s
\\
. performed on April 7,1978, July 7,1978, and January 4,1979.
Acceptance criteria for ceasurement and ansivsis of flow f rom the horiasetal drain are contained in FT-75.6, " Service Water Pu=p House Drain System - Turbid.ty - Suspended Solids", iand Technical The required Specification 3'4.7.7.1., " Service Water System".
frequency of testing is at least occe every six months.
No deviations or ite=s of noncocpliance were identified.
Review of Pie:oceter Data - The inspector c:xmined records of pienemeters located in the vicinity of the SWPH to determine the e.
ef fect of hori: ental drain installation on groundwater levels.
Prior to installation of the drains, pie:ceeter nu=ber F-14 Pieremeter P-14 is indicated ground water was at elevation 274.
Piereceter P-13 angled to a point under the center of the SVPH.
indicated groundwater sas at elevation 276 prior to drein instal-Pie:oceter number F-13 is a vertical piezometer which was lation.
installed on top of the dike approxi=ately 40 feet vest of the Af ter installation of the drains, pie ometer P-13 indicated Sk?H.
a drop in groundwater fro: elevation 276 to elevation 274 while pie:o=eter P-14 indicated a drop in groundwater from elevation 274 Since this is below the level of the horizontal to elevation 270.5.
drains, the caly explanation that S&W engineers could offer for the behavior of piezo eter F-14 after drain installation was that the transeucer for this piezoceter was installed approxi=ately 4 feet higher that previously believed.
The inspector exa=ined =onthly records of pie ometer readings taken froc Juse 1978 through February,1979 to determine the Acceptance ground water level of the service water reservoir.
level are contained in criteria for cessurement of the groundwate:
PT-75.7, " Service Vater Reservoir - Grou=dvater Level", and Technica; 3/4.7.13, " Groundwater Level - Service Wate:
Specificatio Reservoir-li=iting Condition for Operaton."
Pie:cceter nu=hers P-13 and P-14 have indicated drops in grcund-water level of approximately 1.5 feet since late Nove=ber,1978.
The inspector questioned North A :a site personnel concerning the These discussions disclosed apparent drop in groundwater level.
site personnel ce= pare the pie:o=eter readings to Technical that is within the TS Specification (TS) require =ents and if the data Results are then filed in limits, no further action is required.
(DCU) after distribution of copies of the Docu=ent Control Unit the data to various persot:tl '
04 -'- cd VLPCO and 3csten S&W Site persoscel do not perfor= and procedures do co.
offices.
require a trend analysis which would disclone variations t dat:
7ir 4
I i
JlJ 6
g
from average monthly readings.
Site personnel had no coc=ent concerning the pieremeter data, except to state that the data were within IS li=its, i
Discussions in the Richmond VEPCO offices with the VF.?CO Supe: visor of Civil Enginnering Services and in Boston with the S&W Geotechnica'l drops in groundwater levels Engineer disclosed that the apparent in these piezometers are suspected to be either a result of errors by the individual caking the readings o malfunction of the pore used to read the pie:cceters). The pressure indicator (instrumer:
VEPCO S yervisor of Civil Engineering Services notified the site of the potential problem with the pie:ometer data in late February, 1979.
Further discussions at the site on March 14 and 15,1979, with licensee macagement disclose that the macufacturer of the pere to send a pressure indicator vill be cocracted in the = ear future representative to the site to service aad calibrate the instrument, if required, review the procedure being used to read the instru=ent, and verify that the individual reading the pie emeters is doing it correctly.
ever the delay in discovery of the The inspector expressed concer potentially incorrect pie:ometer readings and questicced whether or not a trend aa-lysis should have been performed to detect The apparest lack of adequate potential errors in readings.
procedures to specify corrective action, e.g., perform a trend a alysis, was identified to the licensee as Ucrasolved Item This item is being evaluated by hRC to deter =ine if 33S/79-13-01.
NRC will also review adequate procedures have been established.
the report of the pore pressure indicator cacufacturer in evalua-tion of this item.
The most current SWPH settlement survey data at the site on March 6, 20, 1978, readings.
The inspector verified 1979, were the Nove=ber these data were the most current available on site on.this that date by review of DCU files and discussions with the e=gineer responsible for review and analysis of SW?H settlement data.
During discussions with the VEPCO Supervisor of Civil Engineering Services and his staf f on March 7,1979, the inspector questioned if any additional SW?H settle =ent surveys had been =ade since Neve=ber 20, 1975.
The inspector was infor:ed that surveys were
=ade in January a;d February but that this data had not yet been Diring a discussion of the ef f ect of the received fro = MH&C.
apparent drop of groundwater table elevation on SW?H settle =ent, the licensee's representative indicated that they were not. concerned
\\ U(
71 fI,i 4Jt
12 that additional S'JPH settlement had resulted from a drop in the groundwater table since they assumed the pieroc:eter data was At the request of the inspector, the licensee obtained incorrect.
copies of the Janua:y 3,1979, and February 6,1979,' survey oata.
The inspector and the licensee reviewed the data and verified that.
additional S'd?H settlement had not occurred since Nove=ber 20.
No deviations or items of noncocpl.f uce were identified.
0 4
4OI
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s UNITED STATES gAA 880 0g#o NUCtEAR REGULATORY COMMISSiCN st REGloN 11 Sol MARIETT A STREET, N.W.
o 5y ATLANT A, GEORGIA 3o3C3
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i
SUMMARY
OF INQUIRY Virginia Flectric & Power Company (VT.?CO)
Subject:
North Anna Unit 1 Docket No. 50-338 Allegations that V?.PCO had knowledge of significant safety information regarding foundation conditions (Service Water Pcp House settlement) at the North Anna site in August 1977 and withheld the informa-tion from the NRC for seven months until April 28, 1973.
March.5-13, 1979 Dates of Iaquiry-m k
j ). f/
) 3.g7.79 r,v Perfor=ed by:
C. E] A1 Aerson Date Regional Investigator Office of thi Director NS
(
7'T 3-p 7. pg 4
y
. v:..ewed by:
Date r.e
?. J. Long A-ting Deputy Director Office of the Director
', /)
I i
E I
f f
4 eN M
k
_2 I.
INTRODUCTION In a letter to the Coc=issioners dated Nove=ber 1,1978, the North Anna Environ = ental Coalition (NAEC) stated that fro = infor=ation available to the UA C it appeared that significant safety infor=stion regarding foundation conditions at the North Anna site had been withheld fro = the.
NRC for a period of seven months and was never raported to the Ato=ic Safety and Licensing Board (ASLB).
The letter alleged that VI?CO hac been aware of abnor=al and differennial settlesrnt i, August 1977 and Its letter further reported it to the NRC until April 1978.
had not alleged that the nitter was reportable under the Unit 1 Technical Speci-fications and tad been reportable under the requirecents of 10 rTR 50.55(e) prior to issuance of the Uni I cperating license.
In a letter to the Advisory Co==ittee on Reactor safeguards (ACRS) dated Nove=ber 3,1973, the NAEC stated that it would appear that VEPCO under-took no evaluation for conths after beco:in aware of the excessive This letter to the ACRS incit.ded a copy of NAEC's Nove=ber 1st settle =ent.
letter to the Co==issioners.
This inouiry and a special inspection were initiated under the authority provided by Section 1.64 of Title 10, Code of Regulations and were conducted jointly to:
(1) deter =ine the specific reporting require =ents pertaining to the U=it 1 and 2 Service Water Pu=p House settle =ent which were in effect at the various times n. question; (2) review Stone and Webster (S&W) and VEPCO procedures for the accu =ulation, evaluation z d reporting of settle =ent data; (3) deter =ine the specific handling of the data resu'. ting from the survey perfor=ed by Stone and Webster in August 197 and (4) deter =ine if an investigation i
- .o the =atter was warranted.
The results of the inquiry are presented below.
Technical evaluation of the North Anna settle =ent =ccitoring progra=, including S&k' surveys ar.d Moore, Hardee and Carrouth Associates (MH&C) surveys is addressed in the report of the special inspection (IE Report No. 50-338/79-13) to which this Su== arf of Iaquirf is appended.
II.
SCOPE This inouiry included the following activities:
Review of 10 CFR 50.55(e) reporting requirements, a.
b.
Review of North Anna Unit 1 Technical Specification reporting require =ects.
c.
Review of:
(1) Correspoodence between VIPCO and the NRC; (2) the transcript of the ASL3 hearings for the Unit 1 operating license; 4 /,
7 1 r, 40i ji" z
. and (4) the (3) the North Anna Unit I and 2 Safety Analysis Report; Jorth Anna Units 1 and 2 Safety Evaluation Report including supple-cents, to deter =ine whether VEPC0 had cade any commitments beyond of the Unit 1 the settlement monitoring and reporting recuirements4 Technical Specifications.
Review of files related to settle =ent in the possession of the S&W ~
Construction Group at the North Anna site and discussions with the d.
S&W Site Construction Project Engineer on March 5,1979.
Review cf files related to settlement in the North Anna Station Records (VIPCO) and discussions on March 6,1979, with the engineer e.
on the North Anna operating staff assigned responsibility to evaluate settlement data.
Review of files in the pcssession of and i=terviews with VEPCO's f.
Supervisor of Civil Engineering Services and the Chief Surveycr at March 7,1979 the Corporate Offices in Richmond, Virginia c:
Review cf files in the possessica of and interviews with S&W's Lead Geotechnical Engineer for the Scrth Anna project and a previous g.
Engineering Project Engineer for North Ar=a Unit I at S&W's Corporate Offices in Boston, Massachusetts cc March 13, 1979.
Discussions with the current and pric Licensing Project Managers h.
and the Leader of the Geotechnical Engineering Section in the Office of Nuclear Reactor Regulation.
A telephone discussion with the off.cial of the NAEC who had i.
written the letters to the Co==issieners and the ACES.
II:. DETAILS 7-cuire=ents and Ef fective Da tes Review of Mo:itoring and Recorti: 2 a.
Paragraph 50.55(e) of 10 CFR 50 was reviewed for applicability to the situation.
Based on this review, it would appear that VEPCO':
telephece notificaticn to Region II on April 16, 1975 and their subsequent written report to the NRC dated May 15, 1975 concerning sett.'enent of the Unit 1 and 2 Service Water Purp House satisfied the reporting requirenects of 50.55(e).
The purpose of 50.55(e) is the NRC is =ade aware of eny significant probl-=s to e=sure that ide :ified during ce=structica cf a f acility so that the probit =s can be evaluated a d =ccitered to assure apprepriate resolutica.
Periodic status reports are =ot required by 50.55(e) af ter initial
=ctificatice is cade.
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. The conitoring and reporting requirements of th. Korth Anna Unit 1 26, 1977 when Technical Specifications became operative on November could the operating license was issued, and derefore, no reportThn question as have been required thereunder, before that date.
to whether a sixty-day report oc the S&W survey results of August (1) the day the license was issued 1977 would have been due on:
(since more than sixty days had elapsed since the surveys had been or (3) c.ade), (2) sixty days following issuance of the license, sixty days frno the time VE.FC0 beca=e aware of the results, require
- However,
'-tion of the Technical Specification.
a legal inte.
c::stion obtained during this inquiry, the answer based on the im to this question does cet appear to have any bearing in this matter.
The investigator reviewed VEPCO/NRC correspondence on this issue and discussed it with both the current and prior NRR Licensing Project Managers, and the Geotechnical Engineer who had been i d
to deter =ine if any special reporting requirements had been impose The review and on VEPCO regarding settle =ect survey results'.
discussions did not disclose any pecial requir-mts; however, a VIPC0 to the NRC datet July 11, 1975 was found to letter fro contain the following statement:
will be cc:tinued on a monthly
" Monitoring of the settlement basis througheut the canstructW and initial operation of These observations vill be reviewed at that Units 1 and 2.
ti=c to determine if a less frequent monitoring sequence can The staff vill be consulted prior to any change be justified.
~
in the monitoring schedule."
This statement was contained in VEPCC's response to a question from N?.P. which requested a discussion of proposed Technical Specification The investigator was unable to locate any subsequen limitations.
NRC/VEPCO correspondence cr;2 ding eccitoring frequency until the proposed Technical Specification with a six-conth surveillanceThis re frequency, was sub=itted in October 1977. NRR and acte could recall discussed with the three individuals frc:
the letter or a discussic: of a one-=onth frequency.
T ey further stated that there was never a require =ent that surveys be accom-plished =enthly.
11, 1975 and the sub=ittal of It should be noted that betweEn June the proposed Technical Specification, additional structures had he Technica been identified as requiring monitoring f or settl- -
Specification which was eventually issued required was written.
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Responsibilities for Perfor=ing Survevs The investigator interviewed several individuals to determine the The relationship between S&W surveys and these perfor=ed by S&C.
(VIPCO) stated that =enthly Supervisor of Civil Engineering Services to the '
settle =ent =casure=ents were initiated in Dece=ber 1972 'dua.
At that tine S&W was appearance of cracks 12. the SW?H ving-vall.
instructed by VEPCO to perfor= the necessary surveys for what was However, the Supervisor said believed to be a te=perary progra=.
that in 1975 it beca=e apparen* to Vy.PCO that the NRC would require a long-ter:r =enitoring progra=, possibly lasting the life of the S&W would eventually The Supervisor explained that sinc :
plant.
leave the site when ecast:_ :tica sas ccepleted, VEPCO decided that it would be better to ' ire a local co=pany to perfor= the surveys.
5&C had been perfo=iug survey work for VEPCO in oder areas since 1967 and VIPCO decided that they should perfor= the surveys required by the Settle =ent Monitoring Frogra= being developed at that ti=e.
The investigater eviewed the "open-ended' service centract between VEPCO and ME&C and deter =ined dat it had been entered into on Septe=ber 1, 1967. The investigator also reviewed a letter frc=
23, 1975 w=ich authori:ed S&C to VEPCO to 5&C dated Septe=ber initiate a survey progra= to moni;or the Nord A:na Service Water The Reserveir da= and pu=p house under the se:vice ccetract.
of the original su:veys, the letter specified that upon ce=pledo:
align =ent-settle =ent =arkers were te be==nitored when the water-level in the reservoir reached certain specified levels and once each year after the reservoir was filled.
The investigator found several S&V and VI?CO 1etters in the various files reviewed which clearly establish that SEW was assisting VEPCO in de develop =ent of de Set.le=en. Mocitoring ?regra= and the preposed Technical Specifica:. ion, incluc'ing the identification of structures and ec=ponents to be monitored, the frequency of =enitorin The letters and various and the li=its on dif f erential settlement.
internal mercoranda also indicate dat it was VEPCO's intent te have a single =enitoring progra= vbich satisfied the infer =ational needs of VI?CO, S&W and the NRC, and that the surveys vould be performed by S&C.
~he individuals interviewed were unable to state why the S&V pu=p hcuse settle =ent surveys c etinued after S&C was contracted to perfor= the set:.le=ent su-veys; however, it was pointed out to the but five of the =any investigater that S&W surveys did ::t include points required by the Technical Specifications and were never intended to satisfy dose require =en.s.
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I JCL 3
__ Procedures for Accu =ulating. Evaluating and Revertine Settlement c.
Data The S&W Project Engineers for Construction (site) and Engineering (Boston), and the Lead Geotechnical Engineer vere interviewed to deter =ine the nor=al procedure f or handlins; the settle =ent suney data within the S&W organization.
Supervisor of Civil Engineering Services asd the Chief Surveyorh vere interviewed to dete=ine the nor=al procedure for handling t e Discussions settle = eat survey data within the VEPCO organination.
ff were also held with the engineer on the North Anna operating sta responsible for evalusting the survey datz and discussions had bee held previously with the S&W survey party chief who had been in These interviews and records reviews in the August 1977 surveys.
disclosed dat prior to October 11, 1977 there vere no formal h
written procedu--s within S&V or VEPC0 covering this aren, but t e descriptions prWed by the::e individuals as to hev the data was handled vere a R in general agreement.
Vid regard to S&W surveys, the SW surveyors vould make the surveys At some later time the and enter the raw data in a field book.
suney party chief would transfer the raas data to a form which was The recorr's indicate that from then forwarded to S&W-Boston.
initation of the survey program in late-E972 until late-1975 this fo= with the rav data was sent caly to en2e individual at S&W-Boston In late-1975 (around August) a standard transmittal by telecopier.vas introduced and the distribution of the raw data was expan From for:
to include several individuals, including VEPCO e_.ployees.
this point in time on, the data was = ailed to the recipients, The except for special requests which vere sometimes telecopied.
trans=it:21 sheet was revised at least o=ce and the distributi The trans=ittal sheets contained no data themselves was changed.
For this reason, the trans-and =erely served as " routing" for:s.
cittal sheets were =ct retained with the data sheets, if at all, and the investigator was unable to :dentify from the records dose individuals who received any particular set of raw data or when they received it.
The records available did indicate that between February 1973 and cid-1975 the S&W survey data was ceing received by TW-3ostonAfter within one to two weeks f ce the ti=e the survey was made.
=id-1975, the records indicated a continuing trend of increase in of the data in Boston.
de time between the sur-'ey and receiptthe S&W survey data was Beginning in late-1976 it ippears datforwarded to S&V-Bos required being dependent on after a data shee. was full; d e ti=eGenerally, it appeared that S&W-Fosto de f requency of surveys.
received the data vidin one to two sc=ths af ter the first sur~ey e_ de data sheet was made.
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. Regarding MH&C data, nor=al flow of th-rav surv The Supervisor of Civil Engineering of Civil Engineering Services.
Services then forvarded copies of the data to S&W-3oston, andto the o following issuance of the operating license, at North Anna.
The various individuals interviewed indicated that prior to licensing of Unit 1, S&W's Eead Geotechnical Engineer was responsible for reducing and evaluating the survey data from both S&W and tiH&C.
Wi din VEPCO, the responsibility lor the Settlement Monitoring Program was assigned to the Supervisor of Civil Engineering Servies.
Upon issuance of the operating license, responsibility for evaluats.n d
the data for co=pliance to the fechnical Specifications was assigne This engineer to an engineer on the Nord Anna operating staff.He did not normally only received and evaluated the S&C data.
receive S&W data.
The Lead Geotechnical Engineer star.ed that rav S&W data vould sometimes be received regularly, but that at other times, no data f the vould be received for quite a while and then several sets o explained that it U-raw data vould be received at one t"-
depended on the workload of the Survey Party C At times, the Lead Geotechnical Engineer vould call The the S&W Survey Party Chief and request the data be forwarded.
data sheets.
Lead Geotechnical Engineer further stated that there was no specific schedule established for hi= to reduce the raw data and dat settlement and that he did it at irregular intervals.
Supervisor of Civil Engineering Services (VE?CO) stated : hat he nor= ally received copies of the S&k data, but that he only glanced Th:
S&W was responsible for reducing the data and infor=ing at it, a-VEPCC if any proble=s were encountered.
Handling of S&k Su-vev Data for Aueust 1977 d.
The Lead Geotechnical Engineer (S&W) stated that he did not believ-from the field between May 1977 dat he received any S&W survey dataEe explained dat he had requested and January or February 197S.
the data from the S&W Survey Party Chief several times, but. that ding the Survey Party Chief was busy and had no. got*.en around to sen of the o f fice f o
-"-- veer.s the data.
He stated that he was out in Janua y 1978 and v' hen te cane back he started reviewing ME&C He further data and bringing his settle =ent plots up to date.
stated that around the end of Februa y 197S he was revi-ving and pictting the data for the S&C pc=p house su-vey of.D cember 12, 1977 and noticed a significant change, but did not. know if it was il
. He then notified VEPCO's an actu21 settlement or a bad survey.
Chief Surveyor of the possible proble= and requested that the Survey Party Chief send all S&W survey data not previously received by S&W-Bosto fro = the field.
An internal memorandum from the S&W Survey Party Chief to the Lead Gec, technical Ingineer indicated that.
28, 1978.
S&W survey data was forwarded te S&W-Boston en February A =emo fro = the Lead Geotechnical Engineer back to the Survey Party Chief indicated that S&W surveyors perfor=ed an additional survey on March 1,1978 and that the field books were reviewed to deter =ine the validity of the bench = arks.
The me=o also indicates that the Lead Geotechnical Engineer had reached the conclusion that the MH&C data for Dece=ber 12, 1977 survey was valid.
The Lead Geotechnical Engineer stated that he prepared a letter to VEPCO and on March 6,1978 he notified VEPCO's Supervisor of Civil 12, 1977 Engineering Services that the MH&C data for December indicated that the pu=p house had attained 65 percent of the average allowable total settlement and that S&W survey data confirmed the validity of the measure =ent.
7EPC0 subsequen:Jy requested MH&C to peric== additional surveys.
An MH&C survey perfor=ed on March if,1978 indicated that the pu=p mecent li=it and a special house settle =ent had exceeded the 7L
,C days.
This required report to the NRC was required withi. how rer, the NRC had been report was provided on May 31, 1973; notified of the settle =ent and = embers of NRR had visited the site as early as April 13, 1978 to review the =atter.
A Licensee Event Report was sub=itted on April 28, 1978.
Discussion With NAIC Cfficial e.
In reviewing the draf t of this su==ary, it was noted that the phrase "from infor=ation available to the NAEC" which appeared in the NAEC's letter to the Co==issioners dated November 1,1978, could i= ply that they had infor=ation beyund that which they addressed in the letter and which might not be known to the NRC The NAEC representative who had sig=ed the letter wss staff.
contacted by telephone on March 23, 1978, and was asked if the NAEC
=ade available to the NRC.
had any infor:stion that had not bee:
The individual stated that she did not believe they had any infor-
=ation beyond that available in the documents in the Public Docu=ent Eco=.
Vith regard to the allegation that 7EPCO vas aware of the settle-this was based on August 3,1977, the individual stated that on the infor=ation contained in VEPCD's special report dated May 31,
=e :
she stated that 1978.
Regarding reportability of the settle =ent, hb b2b
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~ the NAEC had contacted the consultant to the ACRS after reading his report to the ACRS dated July 19,197S and that he had said he felt the settle =ent should have been reported in August 1977.
t IV.
CONCLUSIONS The records available clearly indicate that VEPCO intended that a.
there be one monitoring progran and that VEPCO expanded an existing contract with S&C to acco=plish the necessary surveys.
b.
Prior to issuance of an operating license, VEPCO relied on S&W to evaluate the survey data and fo:varded the results of MH&C surveys to S&W.
Subsequent to issuance of the Unit 1 operating license, responsi-c.
bility for evaluating survey data to determine cocpliance with Technical Specifications rested with the plant operating staff and only S&C dati.as forvarded for their evaluation.
However, VEPCO continues to forward the E&C results to S&W for further evaluation.
d.
When reduced and evaluated, the results of the surveys perfor=ed by S&W on and af ter August 3,1977 indicated that the service wat.u-however pu=p house settlement had exceeded 75 percent of the limit; the investigator could not conclusively establish tue date that S&W-Boston or VIPC0 became aware of the August 3,1977, and subse-quent S&W survey ruults, but there was no indication that either received the raw data for these surveys until near the end of February 1978.
e.
There did not appear to be any significant differences in the handling and processing of S&' data of.ugust 3,1977 and later, when co= pared to the handling and processing of earlier S&W data.
f.
The allegations are not substantiated and no further investigative effort is warranted with regard to this =2tter.
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