ML20090A822
| ML20090A822 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/22/1980 |
| From: | Horn D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101050514 | |
| Download: ML20090A822 (82) | |
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A T';: Mr. Stephen F.. Howell Ti:e President 1945*=*est Parnall Road
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- J Gentle:en:
i This refers to the investigation conducted by Messrs. G. A. Phillip, I. G. Callagher and G. T. Mawell of this office on Dece=ber 11-13, 15-20, 1976, and January I.-5, 9-11 and 22-25, 1979, of activities at the Midland Nuclear Plant, Units 1 and 2, authorized by NRC Construc-tien ?ermits Ne. C??R-81 and No. CPPR-82. The investigation rel.ated te the settle =ent of the. diesel generator building at Midland and the
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ade:;uacy of the plant area fill. The preliminary results of this 4
investigation vere discussed with Consumers Power Company and 5echtel
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Cor;eration representatives in our office on February 23 and March 5, l;
1979. The report on the matters discussed during those meetings were included with ny letter to you dated March 15, 1979. That letter aise
' set forth the principal matters of our concern as a result of this investigation.
Inclosed is a copy of the report of this investigation. In accordac:e
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vith Secticn 2.790 ef the NRC's " Rules of Practice," Part 2, Title 10.
Code of yederal Regulations, a copy of this letter and the enclosed
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4M investigation report vill be placed in the NRC's Public Document Roo=,
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except as follows. If this report contains information that you or
- I hk your centractors believe to be proprietary, you must apply in writing to this office within twenty days of your receipt of this notice, to withhold such information fron public disclosure. The applicatien must include a full statement'of the reasons for which the infor=atien is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
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Consumers Power company r
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i The results of this investigation continue to be under reriae by the i
NRC staff. Upon completion of this review you yill be advised of any enforcement action to be taken by the Commission.
Should you have any questions concerning this investigation, we would be pleased to discuas them with you.
Sincerely, 4
James C. Keppler Director y
Enclosura IE Investigation Reports No.. 50-329/78-20 and No. 50-330/78-20 cc w/ enc 1:
I Central Files
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Reproduction Unit NRC 20b PDE
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Local PDR N3IC
.........,,. TI C Ronald Callen. Michigan Public Service Commission Dr. Wayne E. P.th Myron M. Cherry, Chicago i-t 9
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U.S. NUCI. EAR RECCIATORY COMMi'SSION~O y,
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OTTICE OT INSPECTION AND ESTORCIMEh7 I
REGION III s
Report No. 050-329/78-20; 050-330/78-20
Subject:
Consumers Power Cortpany Midland Nuclear Power Plant, Units 1 and 2 Midland, Michigan s
Settlement of the Diesel Generator Buildir.g Period of Investigation: December 11-13, 18-20, 1978 a.d January I.-5,
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9-11, 22-25, February 23, March 5, 1979 l';
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Investigaters:
G. A. Phillip 3*I 7D C
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'I-/i-7Y G. T. Maxwel'
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Reviewed By: D es, C f
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Engi ering Support Section 1
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Reactor Construction and Engineering Support Branch h'E.Noreliush YtN Ibi!7 7 C.
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'r REASON FOR IN'IESTICATION i
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,0n September 7, 1976, the licensee notified Region III, by telephone =
that the settlement of the Diesel Generator Building and foundatiens experienced constituted a matter reportable under the requirements of 10 CTR 50.55(e). L'ritten interim reports were subsequently sub:itted by the licensee by letters dated September 29 and November 7,1978.
An investigation was initiated to obtain information concerning the circumstances of this occurrence to derer ine whether: a breakdevn I
in the Quality Assurance prograe had occurred; the occurrence had been preserly reported; and, whether the TSAR state ents were censistent with l
the design and cer.struction of the plant.
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This investigation was performed to obtair. infor=ation relating to design and constructien activities affectinF the tiesel Generator
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Building foundatiens and the activities involved in the identifica-(,
tien and reperting of unusual settlement of the building. The investigatien censisted of an exacination of pertinent records and.
precedures and interviews with personnel at the Midland site, the i
Consu=ers Fever Company offices in Jackson, Michigan, and the Bechtel l-Pever Corporation of fices in Ann Arbor, Michigan.
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SUMMARY
OT FACTS By letter dated September 29, 1978, the licensee submitted a report as required by 10 CFR 50.55(e) concerning an unusal degree of settle- -
ment of the Diesel Generator Building (DGB). This' report confirmed' l
t' information provided during earlier telephone conversations cm or about August 22, 1978, with the NRC Resident Inspector and on September 7 l
l 1978, with the Region III office. This report was an interia repert and 1
vas followed by periodic interim reports providing additional informatie cencerning actions being taken to resolve the problem. Further testing and monitoring programs and an evaluation of the resulting data have been undertaken by the licensee to determine the cause of'the settlement and.the adequacy of the corrective action being taken.- The results of trese efforts will be submitted in a final report to the NRC.-
Information obtained during this investigation indicates:
(1) A lack of control and supervision of plant fill activities contributed to the inadequate compaction of foundation materiali (2) corrective acti' n e
regarding nonconformances related to plant fill was insufficient or l
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certain design bases and construction specificatirns requirements; (3) related to foundation type, material properties and compaction require-m,ents were not followed: (l.) there was. lack of clear direction a.i suppert between the contractors engineering effice and construction sfte as well as within tne contractors engineering of fice: and. (5) the '5/J cont' airs inconsistent, incorrect and unsupported statements with respe:t to foundation type, soil properties and settlement values.
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DETAIt.5 1
I Persens contacted During this investigation approximately 50 individuals were contacted.
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Twel've CPCe personnel which included corporate engineering and quality assurance personnel as well as site senagement, quality assurance ar.d quality control personnel. Ihirty-two Bechtel persennel were conta:ted.
3 These largely consisted of site engineering, quality assurance, quality contr:1, survey and laber supervisors and personnel in project engir.eeri::;.
3.ree quality assurance and Geotech at the Ann Arbor, Michigan effice.
j individuals em;1 eyed by t'.S. Testing Company were mise ir.terviewed.
Introduetten i,
l On August 22, 1978, the licensee informed the NRC Resident Inspecter at the Midland site that unusual settlement of the Diesel Get. rator Building (DGB) had been detected through the established Toundatien Data Survey Pregram. While the licensee regarded the satter as of 10 CTR 50.55(e) until further data was obtained.
serious it was not considered to be reportable under the provisions i
l Tollowing the acquisition of additional data from further surveys and k
a core boring program which was initiated on August 25, 1978, the licensee concluded the matter was reportable and so telephonically i
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no:1fied Regien III on September 7,1978. The notification was fc loved up by a series of interim reports the first of vLich was submitted to Region III by letter dated September 29, 1978. Subse-ihterim reperts were transmitted by letters dated November 7, e
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quent 1978 and January 5, 1979.
i An inspection was conducted by* Region III during the period October 2!. 27, 1978, to review the data then available; to observe the current conditier.
Information regarding
- l' of the structure; and, to review current activities.,No.' 50-329/76-12; the ini.pection is contained in NRC Inspection Report
$0-330/78-12.
on December 3-4, 1978, a meeting with NRR and Region III representatives n was held at the Midland site to review the status of the probles, to discuss 'open items identified in the aforementioned inspection report j
and possible corrective actions.
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Identifiestion and Reporting of Diesel Generator Svildina Settleeent l
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. Surveys to establish a baseline elevation for the DGB were completed i
ey secntel on nay v. 1978. As a result of these surveys, the Chief l
He-or survey rarties notes vnat he considered to be unusual settlement.
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indicated that from his experienc's h.e would have n Ferled about 1/8" settle-The July 22 data showed a "dif ferential settlement betueen various locations ranging from 1/4" to a maximum ofil 5/8"...He promptly instructed ment.
his survey personnel to resurvey.to determiie whether the data was accurata.. The The resurvey confirmed the accuracy of the survey data.
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Parties reported the survey results to the 3echtel lead civil fiald engineer.
The lead civil field engineer said that in July 1978 the settlement N
of a pedestal in the DGB was noted' frere surveys and r. bout a week later a 1" discrepancy was noted when scribes on the DGB vere being moved He said that at that time he was uncertain as to whether actual up.
settlement had occurred, the survey was in error or the apparent He instructed the Chief of Survey discrepancy was a construction error.
Parties to check his survey result,s and to perform surveys more frequently than the 60-day intervals required by the survey progra as a means of deter =ining whether actual settlement had occurred and y'
Whether settlement continued.
The Field Project Engineer was also infor=ed of the apparent settle:ent i
.'Y He said and eencurred with the lead civil field engineer's actions.
he had teured the building at that time and he saw no visible indicatf=ns of stress which coe'.d be expected when unusual. settlement ocrurs.
The lead' civil field engineer said the DGE was monitored for about a month. He compared the a= cunt of settle =ent being experienced with the t"
'y, settle =ent values reflected in Tigure 2.5-48 of the TSAR and did mot When the eensider it repertable until those values were exceeded.
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's'Ecle=ent did exceed these values as indicated by survey data obtained he prepared a nonconformance report sith on abeus August.18, 1978, l
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the assistance of OC personnel.
I The July 22 survey data was transmitted by the site to the 3echtel Project Engineering office in Ann Arbor by a routine transmittal reme' 1
dated July 26, 1978. The data was received at Ann Arbor, processed through. document control on August 9, 1978, and was routinely route f
to the Civil Engineering Grony Supervisor.
the data but placed a route slip on it indicating those members of his group who should review it.
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The engineer in the Civil Group, who had established the survey progra:
sad who was responsible for assuring it was being carried out, stated For that reason ha reviewed the data and did not regard it as unusual.
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he did not bring the matter to anyene's attention but merely routed The engineer responsible fer it to.other personnel in the civil group.
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'the DG3 said he did not see the data before the settlement proble= vas identified by the field in a nonconformance repert.
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With the issuance of the noncomformance report, No. 1482, on August 18, 1978, CPCo was also informed of this condition. On or about August 21, 1978, the NRC Resident Inspector was orally informed of the matter by CP Co.
It was indicated at that time that although CPCo regarded the,
matter as serious, they did not consider it to be reportable under 10 CTR 50.55(e).
Construction on the DGB was placed on' hold on August 23,1978 and a test boring program was initiated on August 25, 1978. After prelir-1 inary evaluatien of soil boring data, a Manage =ent Corrective Attien Repert (MCAR), No. 24, was issued by Bechtel on September 7, 1975.
The MCAR stated that based en a preliminary evaluati:n ef the data.
the catter var reportable under 10 CTR 50.55(e),1, iii and Regi:n !!!
vas so netified by telephone on that date.
The telephone notification was subsequently followed up by a letter dated September 29, 1978, from CPCo enclosing a copy of MCA?. 24 and Interic Report 1 prepared by tachtel.
On the basis of the above, it is concluded that in this instance the licensee co plied with the reporting requirements of 10 CTR 50.55(e).
Review ef ?S A? 'TS AR Ce==itsents en Compacted Till Faterial f
In a previous NRC Inspection Repert, No. 329/78-12; 330 75-12, an F
apparent inconsistency was identified between TSAR Table 2.5-14 (Sc==ary of Toundations Supperting Seirmic Category I and II Structures),
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Table 2.5-9 (Mini =u= Compaction Criteria) and the site constructien drawing C-45 (Class I Till Material Areas) regarding the type cf fcun-dation material to be used for plant area fill. Table 2.5-14' identifies the supporting soil materials for the Auxiliary Building D I, T and C. Radvaste Building, Diesel Generator Building and Borated Vater Storage Tanks,to be "contro11e'd compacted cohesive fill."' Table 2.5-F also indicates the soil type for " support of structure to be clay.
Contrary to these TSAR commitments, drawing C-45 indicates _;one 2 (random fill) material, defined in Table 2.5-10 as "any material free of humus, organic or other deleterious material,"'is to be used dich "ne restrictions on gradation." Boring samples substantiated that Zene 2
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(random fill) material was in fact used.
During this investigation a review of documentation showed that the com=itment to use cohesive soils was also made in response to PSAR question 5.1.11 and submitted in PSAR Amendment 6, dated'Dece=ber 12, 1969, which states, " Soils above Elevation 605 vill be cohesive soils in an engineered backfill." This response also indicated that certain class I components such as, erergency diesel generators, berated water storage tanks and associated piping and electrical conduit would be founded on this material.
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-~C?Co cuality assurance issued ar nonyonformance. rep 3rs.qT-66, dated 10, 1975, whichstated'thistcontrarytothePSARstatenent j,
October (queted above) Specificatien C-211 being impleeented at the site required cehesionles's (sand) esterial to be used within 3 feet of the
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The corrective action taken was.
valls of the plant area structures.
for Bechtel to issue SAR Change Notice No. 0097 which stated, "The TSA:
of vill. clarify the use of echesive and cohesionless soils for support Class I structures." As noted abeve, the TSAR tables 2.5-14 and 2.5-9 once again stated that cohesive (clay) material was used for support of the use structures whi*e the construction. drawing continued to permit cf rand:= fill material.
This investigation included efforts to ascertain whether procedures were established and in;1enented for the preparation, control and reviev (SAR).
of the technical criteria set forth in the safety analysis repert This included the role of both 5echtel and CPCo in the review of the Bechtel had established control of the SAR in procedure MID SAR.
4.22 (Preparation and Centrol of Safety Analysis Report Revision 1
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The SAR preparation and reviav flow chart requires dated June 20, 197.).
the Engineering Crru-Supervisor (EGS) to review the originator's draf t for technical accuracy and cc:pliance with the standard format guide.
Records indicated that Se: tion 2.5.4 was originated by the 5echtel certert grrup en January 3,1977. It was reviewed and appreved for technical accuracy by an engineer in the civil preject group en April 29.19227~~~
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Ne technical inaccura:1es ve,re noted in the documentation.
The Civil ICS advised that he did nrt personally review Section 2.5.4.
1 The designated engineer stated that in his review of the section he ves prinarily cencerned with the Auxiliary Building not the Diesel
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He said the review of TSAR material was perferred J
Generator 3cilding.
Not all of the content by nezbers of a grrup set up for this purpose.
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was checked since they relied to some extent on the originator.
auther of Section 2.5.4 said he was not aware that changes regarding *.
It was fill material had occurred since the' preparation of. the PSAR.
ascertained that Tield Er.gineering did not review the TSAR prior to I
its subnittal.
i A partial.-eview of the TSAR revealed that although Tigure 2. 5-48 indicates anticipated settlement of the Die 621 Generator Building during the life of the plant to be on the order of 3 inches.
Section 3.8.5.5 (Structural Acceptance Criteria) contains the following state-
" Settlements on shallow spread footings founded on compacted ment:
fills are estimated to be on the order of 1/2" or less."-
Geotech, who prepared Section 3.8 was prepared by Project Engineering.
Section 2.5,-said they were unaware of the presence of the statement The originator of Section 3.8 retarding 1/2" setclonent in Section 3.8.
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said that the above statement was taken from the Dames and Moore report i
submitted as part of the PSAR. Since the PSAR did not show any change in this regard, he assuesd the statement was valid for inclusion in the PSAR. He said there was no other basis to support this statement.
CPCc also has an established procedure for the review and final appreval of the SAR by procedure MPPM-13 dated June 23, 1976. Section 5.6 statas that "CPCe shall approve all final draf t sections of the TSAR prior to final printing." Discussion vith the responsible licensee representa-tives fer review of Section 2.5.4 indicated that a limited amount cf cress-refetence verification of technical centent of the TSAR is perforced by CPCo.
The CPCe Project Engineer in Jackson stated that the review of drawings 4
and specifications was an owner's preference kind of thing. Ec atte pt was made to review all drawings and specifications since they did not f,.
have the manpower or expertise for that type of review. The staff engineers of the various disciolines were asked to indicate the drawin;s
- C and specifications they wanted to review.
Regarding the reviev of the TSAR, he said that he had prepared a
=escrandu: to the staff engineers stating the procedure that would be fe'. loved in perfer= int the review. An examinatien of this mene, dared 2
July 28,197 6, shoved that prime reviewers would perform a technical y
review, resolve comments made by other reviewers and perfore the CPCe licensing review te assure compliance with required TSAR format and
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centent.
As portions of the TSAR vere received from Bechtel, CPCo sent comments te 3eef.tel. Following this review, meetings between Bechtel and CPCe r,.
vere held to clearup any unresolved matters before each section was released for printing.,A reviev of the files at CPCo relating to Section 2.5 and 3.8 showed that no comments were made concerning the abeve incensistent and incorrect content. The apparent inconsistent 4
and incorrect statements were not identified during the review of the i
TSAR prior to submittal and the review procedures did not provide any mechanism to identify apparent inconsistencies between sections of the
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TSAR.
.f Based on the above, measures did. not assure that design basis included in design drawings and specifications were translated into the license i
application which resulted as an inconsistency berveen the design dravings This is considered an item of noncompliance with 10 CTR 50.
and the TSAR.
Appendix B, Criterion III as identified in Appendix A.
(329/78-20-01; 330/78-20-01) 9 9
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Effect of Creund k'ater in Plant Area' Till
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i grade vill be established at elevation 63t..
The norr.a1 Tinal plant ground water was assumed to be at ground surface prior to constructier.*
appreximately elevation 603. The surface of the water in the cooling vater pend vill be at a maximum of approximately elevation 627.
,i D e Dates and Moore report on Toundation Investigation submitted with l
"The PSAR Arendsent No.1, dated February 3,1969, stated that,
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effect ef raising the water level to elevatten 625 in the reservoirs vill cause the normal ground water level in the general plant area t.:
eventually rise to approximately elevation 625. 'However, a drainage syste vill be previded te r.aintain the greund water level in the ;1 ant 1
fill at elevation 603."
to Dames and Moore report was submitted in ?SAR Acendment i
A suoplement No. 3, dated August 13, 1969, which changed the above planning of a drainage system te centrol the ground water. The supplement states.
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".De underdrainage system considered in the initial report has been is assumed that the ground vater level in eli inated; censequently it area vill rise concurrently to approximately elevatten 625."
3-the plant A 3echtel soils censultant theorized in a Dece.ther I, 1975, site resting that if seils beneath the diesel generator building had been cempatted
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ter dry of opticus, changes in meisture af ter placement could cause the seils to settle significantly. Therefore, the total effect of the
.y greund water being permitted to saturate the plant fill material is undeter=ined at this tin..An evaluatiJn of this conditien is under E
review by the licens'5e. This item is considered unresolved.
(329/f8-20-02; 330/78-20-02) j, s
Review of Cer: action Recuirerents fer Plant Area Till During the investigation a review of'the history of the compactica requirements was performed in order to determine whether the cotspaction of the plant fill was implemented in compliance witn'the commitments in the PSAR and in site construction specifications.
1 dated February 3, 1969, presented the Dames and Moore,,
PSAR, Amendment report "Toundation Investigation and Preliminary Exploration for Borrow Materials." The reconsnended minimum compaction criteria for support of critical structures is stated on page 15. It indicates 951 of maximu=
density f or " cohesive soils" as determined by ASTM D-1557-667 and 100' for " granular soils."
13, 1969, included a supplement to the PSAR, Amendment 3 dated August Dames and Moore report entitled, "Toundation Investigation and Preliminary
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r Page 16 of this report lists the Exploration for Borrow Materials."
recommended =inimum compaction criteria for sand soils and cohesive soils.
For the fill material for supporting structures the minimum compaction is
.(
85% relative density for sand and 1007 of maximum density for clay as,
determined by ASTM D-698 modified to require 20,000 f t-lbs of coe;acti
- energy (equivalent to 95: of ASTM D-1557, Method D which provides 5f,0 '.
f t-lbs of compactive energy). Subsequent to the filing of Amendeent 3, l
no amendments were made to the PSAR to' indicate that the recornendatiens i
)
contained in the Dames and Moore report would not be followed or v:uld be further modified.
Bechtel Specificatien C-210, Section 13.0 (Plant Area Backfill end 3ackfill) indicates the compaction requireeents for cohesive sril Ber (13.7.1) to be "not less than 95% of maximum density as deter =ined *:y (13.7.2) to be ASTM D-1557, Method D" and for cohesionless soils (sand) compaited "to not less than 80% relative density as determined by ASTM D-20a9."
, r.
A c:=parison of the PSAh co=mit=ents to the specification require ents shews that the compaction cem:ittents for cohesive soil (clay) were translated into the construction specification i.e. 95% of raxieur density using ASTM D-1557, Method D (compactive energy of 56,000 f r-lbs..
However, the co=paction cencitment in the PSAR for cohesienless sci,1 (sand) was not the sa:e as in the construction specification, i.e. 55' relative density versus the 80% relative density, translated in the 5,
construction specificatien.
I e(
The co:paction requirements attually implemented were as follows:
1 Cshesive soil (clay): 95% of maxi =ue density as deterrined by.
a.
the "3echtel Modified Test " a compactive energy of 20,000 fr-lbs vas used instead of $6,000 f t-lbs of compactive energy as ce==itted to in the PSAR and required by the construction specification C-22',
Section 13.7.1.
l Cohesionless soil (sand): 80y relative densirv as determined b.
by ASTM D-2049 was used instead of 857 as committed to in the However, this is consistent with construction specif1-PSAR.
cation C-210, Section 13.7.2.
Th2 compaction requirements implemented during construction of the plant area fill between elevations 603 and 634 were, therefore, less than the co==itments made in the PSAR for cohesive and cohesionless fill In additon, the cohesive (clay) material was also compacted material.
to less than that required by the Bechtel specification.
(Specification C-210. Section 13.7).
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.__Areview of Specification C-2I0' (specification conrregng earthverk 27, 1973, which was 7-contract) beginning vi:h Revision2, dated Julyit contained conflicting sections
-i * ".
issued for subcontract showed that area backfill compacticn requirements.
r., elating to the plant Section 13.7, Compaction Requirements, free revision 2 to the lates:
revisien ef specification C-210 consistently specified that the backfi'l area shall be cc:pacted to 95% of maximum density as de:er-in the plant mined by ASTM 1557, Method D.
See:f on 13.4, Testing Plant Area 3ackfill, cf specification C-210 ce.n-fer:h in that tes:s vould be performed as set tained the statement Se::1:n 12.4.5, Laberatery Paxi=u= Densi:y and Osti=u= Moisture Centen:,
which in turn specified a lesser standard, 20,000 foot-pounds per cubi:
foe:, which is coe=enly referred to as the Bechtel Podified Pro: tor Density This is contrary to the requirements of Section 13.7.
Section 12 of the specification applies to Dike and Railroad Irbank=e-:
Tes: (5Mp).
j Construe: ion.
y' this control inconsistency was reflected in.the I: vas als: neced that applicable Midland QA Inspection Cri:eria SC-1.10 Item 2.3(d' Conpa::ir:
d whi:h states " Backfill ca:erial fer the specified zones has been ec=pa::e d"
te the required density as de:er:ined by Bechtel Modified Proctor Metho i
references C-210 See: ion 13.7 as the inspection criteria.
8" and ye:
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The in:ensistency in control is further indicated in Specification C-205
.~
which defined the tes:ing con:ract requirements of subgrade materials, i
Section 9.1 (!esting) required compaction tests t'o be in accordance vi:h
- I 1
AS M D-1557 and only when directed was the BMP cempaction criteria to be d
.It was deter =ined contrary to this C.S. Testing was only crally the BMP vas the standard to be applied to the tests they used.
j advised that perfor:ed of plan: area fill.
Through in:erviews and an examinatieri of internal documents it was ascertained that because of these inconsistencies, the question of I
i the applicable compaction standard for cohesive materials in the plant area was a recurring one.
f The f ollowing is,a summary of the documentation regarding the confusien I
of the coepaction requirements for plant area fill:
10, 1974, (subcontracts to Tield Letter 7220-C-210-77 dated June i
Engineering) states "there has been some confusion as to the in:er-1.
i all 13.7 Compa_ction Requireeent:
pretaion of the following ite=: backfill in the plant area and be i
d than 95y of maximum density as determined by modified Proctor mathe e
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r (ASTM 1557, Method D), with the exceptien that 7enes 4, 4A. 5. 5A.
and 6 Materials need ne special compactive effort other than as
[
described in Section 12.8.1 (emphasis included in specificatien).
Quality Control questioned whether the exception stated above applies only to Zones 4, 4A, 5, 5A. and 6 or did construction ha7e to abide by Section 12.8.1 for Zones 1 and 2.
Section 12.8.1
. clearly requires Ione 2 caterial to be placed with a 50 ten rubber tired roller with a minimum of four roller passes per lift. OC's interpretation was that the field needed "to obtain 95? of maxi ur density by the modified. Proctor method (ASTM 1557, Methed 3), with ne restrictions as to the rathed used to obtain these results."
2.
Letter 7220-C-210-23, dated June 24, 1974, (field Engineering te censtrue:1on) responded to Item 1 above. It states, "We have reviewed your June 10, 1974, IOM concerning compac.tive effort required on Zones 1 and 2 in the plant and ber= backfill areas.
We agree with your interpretation; i.e. a 95 of maxieux density g
is the acceptance criteria, and the number of roller passes listed in Paragraph 12.8.1 does net apply to plant and ber= backfill. Ve feel the specification is new clear and no FCR is required."
.t Letter BC3E-370, dated July 25, 1974, (field construction to 3.
preje:t engineering) lists outstanding it ems requiring Proj ect Engineering's actien.
This includes the questien "Is the 95
.t compartien required in the plant area to be 95' of Bechtel i.
Modified or 95!. of ASTM-1557, Method D."
(
4 Letter 3I3C-456, dated August 1, 1974, (Proj ect Engineering te Tield Construction) states that Geotech is addressing the questien posed in 3C3I-370 (Item 3 above).
5.
Merorandu: free Geotech to Bechtel Tield, dated Septe:bar 18, 1974, responds to the question raised in 3C3E-370 (Ite: 3 s
abeve). It states, "It is our 6 pinion that all the compaction requirements that are needed for Zone II material in the plant fill is as stated in 13.7 with the exception that 7enes 4, 4A, 5, 5A, and 6 materials need no special compactive ef fort other than described in Section 12.8.1."
Geotech reiterates.the l
specification requirement of 95! of ASTM 1557, Method D.. This I
was confirmed with the Geotech personnel.
6.
Telecon dated September 9,1974, from R. Grote (Tield Engineering) to Rixford (Project Engineering) states, "I made an analogy (an exaggeration admittedly but applicable) that if the compaction could be acheived with a, herd of mules walking over the fill it would be acceptable as long as it got the required 95% compactien.
Rixford agreed."
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Telecen Consumers to Bechtel Engineering dated Sta,ttember 19, 1974, g _.w.
7.
expressed Consumers Power Company concern about what they felt was
[
a lack of control of compaction in the plant area fill. CPCe addressed the added responsibility this lack of control places e
e on the inspector. Bechtel told CPCo that it "was the inspecter,'s_
b job to make sure we got proper placement, compaction, etc."
8.
Telecen dated September 18, 1974, by Bechtel Tield Ingineering to Bechtel Project Engineering discussed compaction require ents for specificatien C-210.
It' stated, " Compaction acceptance is based on meeting an 'and product' requirement, i.e. 957 ef maxi =ue density only. No method of achieving this 'and product' is specified er is required. Rixford fully agrees with the above."
t 9.
Telaeon dated October 7,1977, from Bechtel Field Engineering to Bechtel Project Engineering states, "QA has asked for clarification of subject specification (C-210), Section 13 for plant area and ber=
backfill'. Section 13.4 for testing of materials refers to Section 12.; and therefore, requires the Bechtel Modified Proctor Density Test for Compaction of cohesive backfill. Section 13.7 for ce= pac-tien of the same materials refers to testing in accordance with A57.
,~
0-1557, Method D Proctor, without specific reference to Bechtel Medification." Bechtel Engineering responded to this question.as 1
fellevs: "This apparent conflict is clarified by Spe:ification C-205, Section 9.1.a. direction to the testing subcontractor.
which calls for.AS W. D 1557 test for these caterials and aise allows Bechtel Field (the contractor) to call for the Bechtel
[:
Modification of that test. Either method is therefore acceptable i
te project engineering."
10.
Telecen dated October 7,1977, from Bechtel QA to Bechtel Project Engineering questiens, "I,s the intent of Paragraph 13.7 of Speci-fication C-210 that the test be.run to the 'Bechtel' modified
~~
proctor test as is indicated in the TSAR Paragraph 2.5.4.5.3 and in response to NCR 88."
Engineering's response,vas "yes."
Various interviews were held with Bechtel construction field engineers,
- r. S. Testing personnel and Bechtel Ann Arbor Geotech and Project Ingineering personnel to ascertain their understanding of the compaction,
Tour predoninant versions of the understood compaction requirements.
requirements were stated by various individuals within the~Bechtel organization. They are as follows:
Specification C-210 required the contractor to perform a.
compaction to the ASTM 1557, Method D, however, the testing 4
requirements would be performed to the less stringent "Bechtel Modified
- Test Method."
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The required compaction and testing was always understood to be based on the "Bechtel Modified Test Method."
(
The required coepaction and testing was always understood tg 'ce c.
based on the standard ASTM 1557 Method D requirements.
- d.
A tacit understanding had been established to use the Ee:htel Modified Method, but to exceed this requirement by enough to also satisfy the requirement of ASTM 1557, Method D.
from the abeve"four distinctly different understandints It is apparent of the compaction requirements, that the apparent cenfusien was net reselved. A rember of the Bechtel OA staf f in Ann Arbcr who had previously been a QA Engineer at the Midland site said that CA audits of QC. inspection criteria did not identify the above inconsistencies.
5 This failure to accomplish activities affecting the quality of the plant area fill in accordance with procedures is considered an itet of nenter-
'g pliance with 10 CTR 50, Appendix 3. Criterion V as identified in Ac;endix Ao a
(3:9 C6-20-03; 330/76-20-03)
Reviev ef Moisture Centrel pecuirements for plant Area Till j
Specificatica C-210. Section 13.6 (Moisture Control) requires : isture control of the plant area fill material to conform to Section 12.6.
5i The moisture centrol requirement in Section 12.6.1 states, in part, "Zene 1, IA and 2 material which require moisture centrel, shall k
be meisture conditioned in the borrow areas " and that " vater
?'
content during compaction shall not be more than two percentage peints belev optitut moisture content and shall not be mere than two percen tage peints above optimum moisture content."
Contrary to the above, Bechtel QA identified in SD-40 dated July 22, 1977, that "the field does not take moisture control tests prior to 4
and during placement of the backfill, but rather rely on the moisture j
results taken from the in-place soil density tests."'
The following is a summary of the documentation that followed the identification of the above deviation from specification C-210.-
1 1.
Letter BCBE-1533R (dated August 15, 1977) fieldtoprojectengineerinh states, "it was found that densities meeting specification require-ments could be attained, irrespective of the use of moisture tests," and that " moisture tests were not used to control backfill moisture." The field requested "that project engineering agree to acceptance of backfill materials installed in the past, along with the records thereof, irrespective of the use of the moisture' rests."
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Letter BEBC-1859 (dated September 30, 1977) respon'sD to the fields request in BC3E-1533R. Engineering states, "It should be noted i
that it is ideal to control the moisture of backfill material at the borrow areas by cenditioning" and that "the procedure used to -*
take moisture content tests af ter compaction would not have direct impact on the quality of work."
Engineering then agreed with the field request that " backfill placed prior to codification of testing methods to be eccepted as is."
3.
Telecen October 10,1977, (Sechtel QA Site to 3echtel Engineeri.3, Ann Arbor) indicated that, "there are no moisture reccirements at the time ef density testing, only density requirement. Tne coisture Jequirement is prior to crenaction."
4 Telecen October 13,1977, (Bechtel EngineerinF to Sechtel OA Site) changed what was indicated in the telecen on october 10, 1977, (Item 3 above). Engineering then stated, "The moisture require-
=ent (+ 2* of optimum) is =andatorv and must be implemented at i '*;
the time of place =ent and testing." This is contrary to what was stated on October 10, 1977.
5.
Letter BC3E-1669R (' dated Nove=ber 18, 1977) once again is a field request to Bechtel engineering requesting, "vritten clari-C
}
fication of the 2'. tolerance on backfill ceisture content duri.'s l'
compaction."
. - {.
1/
6.
Letter 3EBC-1995 (dated Dece:bar 15, 1977) provides engineering's
\\
response to 3C3I-1669R requesting clarification of the toisture
{'
requirement. Engineering stated, "The moisture content of the soil should be within 2*. cf optimu= during place =ent and compaction.
Hevever, this property of the soil is not necessarily a measure of its adequacy after compaction."
7.
Letter 0-1631 (dated December 21,, 1977) closes OA Action Request SD-40 (dated July 22, 1977) which first identified the moisture control deficiency.
8.
Telecen (dated April 7,1978) from Field Engineering and Ouality Contcol to Project Engineer d.ng once again requests them "to clarify,
BEBC-1998" (December 15, 1977), item 6 above. Two situations were presented to engineering as follows:
(a) The moisture sa=ple taken from the borrow area at the start of the shift is acceptable, however, the moisture test taken in conjunction with the density test fails while compaction was attained; and (b) The moisture sample taken from the borrow area at the start of the shift fails and the material is conditioned to meet moisture content required.
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.r however, the moisture test later fails at the time the passing compactien test is taken. Engineering responded, "the above two
(
situations are.acceptab*e as is."
This response'is contrary te the direction previously given in telecon dated October 13, 1977~
I (see Item 4 above).
9.
- Letter CLR-219 (April 16,1978) is a Etchtel Site QA request to Project Engineering to resolve the noisture content situatien and "to previde clear direction for the control of moisture centent." QA reco= mends "one possible solution would be to delete the requirement to control the meisture content and rely en the ec paction requirement only for completion of soils verk."
1 10.
Letter 3EBC-2256 (June 1,1978) was Project Engineering's respense to GLR-2t9 (Ite: 9 above). It states, " moisture content is net necessarily a measure of a soil's adequacy to act as a foundation or ba:kfill sacerial," and that " soil with the specified density 5
following ceepaction would not be rejected on the basis that its moisture centent was not controlled in the borrow area."
Based en the revievs of documentation, ems *ure control had not been i=;1eeent.ed as the specifica;4cnj eguired.
In addition, the =atter been resolve Ffor the period of time from the issuance of C; had not i
Action Request SD-40 on July 22, 1977, until June,1978, during which
-i=e seils safety-related verk continued.
1 Accerding to the licensee, although moisture control was not strictly followed in ac:ctdance with specification requirements, final density 7
tests were used as a basis for acceptance of soil placement.
}.
As peinted out to the licensee, moisture control is a required contrel to assure attainment of percent compaction specified in specifi-point catien C-210.
4 This failure to assure that conditions adverse to quality are promptly identified and corrected to preclude repetition is c6nsidered an itez of nonce =pliance with 10 CTR.50, Appendix 3 Criterion XVI as identified in Appendix A.
(329/78-20-04; 330/78-20-04) af Review of Subgrade Preparation for Plant Area Till The Dames and Moore report on foundation investigation submitted with -
PSAR Amendment 3, dated August 13, 1969, states, "the clay soils are susceptible to loss of strength due to frost action, disturbance and/or the presence of water. - If the construction schedule requires that foundation excavation be lef t open during the vinter, it is recommended that excavation operations be performed such that at least i
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3 1/2 feet of natural soil or similar cover remain in $ ace over the firial subgrade or overlying the mud mat. This layer of protective
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material is necessary to prevent the softening and disturbance of
~
'subgrade soils due to frost action." The licensee indicated that instructions for vinter protection of foundation excavations were trans-mitted by sketch C-271.
The Daees and Moore report also stated "If filling and backfilling i
is operations are discontinued during periods of cold weather, it recer:3 ended that all frozen seils be recoved er reconnacted prior te the resumptien of operations."
After review of the applicable settiens of specification C-210 (i.e.
12.5.1. 12.10. 10.1 and 11) the inspector has deter ined that Sections the 3echtel specification did not provide specific instructions for rezeval or recempaction of frozan/thaved soils upon resumption of work af ter the vinter peried to preclude the ef f ects of frost action on the
.s i 9S.
compacted subgrade materials.
the This failure to assure that regulatory cor:.iteents as specified its license applicatieri are translated inte specificatien, drawings or instructions is tonsidered an ite of noncecpliance with 10 CTR 50 Appendix 3. Criterien llI.
(329/75-20-05; 330/78-20-05) i Review of Noncenfercan:e ?.eperts Identified fer Plant Area Till The fellering examples of nontenformance and audit reports regarding
(
area fill were reviewed relative to the cause of the noncen-the plant formance and the engineering evaluation and corrective action:
No.
Nencenformine Cendition Engineering Evaluatien
- i (1)
CPCe Tailure to perform inspec-
"Use as is" based on QT-29 tion and testing of struc-samples taken from stock t'
(10/14/7I.) tural backfill (sand) pile.
delivered to jobsite 29 of 30 day in Aug. and Sept.
f 74 Sechtel QC not I
informed of deliveries.
(2)
CPCo lloisture control out of Accepted in place material QT-52 tolerance of specifica-with low moisture.
(8/7 /75) tion C-210, Section 13.6.
(3)
CPCo Compaction test had been Tailing tests were cleared QT-68 calculated using incor-by subsequent passing
~
(10/17/75) rect maximu= lab density.
tests.
Test recorded as passing was actually a failure.
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(1)
Bechtel Material placed did not Engineering stated that J
NCR 423 seet moisture require-this ramp area is ts p-J orary and would be recoved.
'(,
(5/5/76) ments.
This was rsmoved based ce note added to NCR 421 of 3/18/77.
In the vicinity of this ramp a Geotech engineer deter-Note:
mined the material to be "sof t" and directed a test pit to be dug.for investigation in September 1978 after the D. G. 32ds.
settlement was identified.
( 5 '-
C?co Lift thickness exceeded Material was re= ved and QT-120 maximum of 4" in areas recompacted.
(9/21/76) not accessible to roller equipment. Insufficient monitoring of placing crews. Laborer foreman not f aciliar with re-
,uire=ents.
q (6'
CPCe Inspection plan C-210-4, Cerrected inspection plan J
07-130 Rev. O, per=its 12" lift require =ents.
2 (1C /18/76) thickness fer areas in-accessible to rollers
,L
(
caused by "misinterpre-tation of specification requirements. Spec. per-mitted 4" lift thickness.
(7)
CPCo Tailure to perform inspec-Engineering accepted the I
QT-147 tion and testing of struc-material in place "use (2/2/77) tural backfill (sand) on as is."
s 12/1/76, 12/14/76 and 1/11/77 (same as QT-29 dated 10/14/74) material 1acked gradation test requirements.
(5)
CPCo Moisture control out-of-Engineering accepted QT-172 tolerance and compaction materials.
(7/8/77) criteria not set.
(9)
CPCo Gradation requirements Er.gineering accepted i
QT-174 for Zone 1 materials not materials.
3 (7/15/77) met.
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3..e-r I " y" (10)
CPCo Moisture content'nst met; ~ Issued' ichtel NCR's Ne.
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QF-199 compaction requireeents 1004 and 1005; No. 10N
[
(11/4/77) f or, cohesive and cohesion-still open; No. 2005 less soil not met.
Mater-
" accepted as is."
g ials had been accepted using incorrect testing data.
(11)
CPCo Gradation requirement not Engineering " accepted QF-203 set yet r.aterials accepted. as is."
(11/22/77)
(1D C?Ce Meisture centent require-Bechtal QC to infore Audit ments not met; test fre-foreman directing soils T-77-21 quency net =et, work of requirements.
(5/77 i 6/77) l (13)
C?Ce Compactics requirement for Project Engineering to Audit both cohesive and cohesion-justify the materials F-77-32 less materials not met; these failing tests (10/3/77) meisture requirements not represent. NCR 07-195 met; costs had been accept-still open.
ed yet fai*e3 require =ents.
i (14) Sechtel Sa=e deficiency as NCR 698. Accepted, "use as is."
h NCR 686 (2/1/77)
(15) Bechtel Structural backfill (sand)
Engineering accepted NCR 695 ves delivered without "use as is."
(2/9/77) acceptance tests on Oct.
i 26, 29, Nov.- 12,197,6 and Jan. 11, 12, 1977.
4 (16) Bechtel Moisture content require-
" Accepted as is" based on density test only.
NCR 1005 sents not met.
(10/26/77) e Based on a review of the above nonconformance and audit reports correc-tive action regarding nonconformances related to plant fill was insuffi-cient or inadequate as evidenced by the repeated deviations from speci-fication requirements.
This failure to assure that the cause of conditions adverse to quality 4
.are identified and that adequate corrective action be taken to preclude-O i
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't repetition is considered an item of noncompliance with 10 CTR 50. Appendix 1.l Criterion X\\*1 as identified in Appendix A.
(329/78-20-06; 330/70-2C-06)
.f Review of Calculations of Settlement for Plant Area s
A review of the settlement calculations for the structures in the plant area was performed during a visit to the Bechtel, Ann Arbor Engineering office. Specific attention ves given to structures founded on plant area "conpacted fill." The following specific findings were made:
1.
TSAR, Section 3.8.4.1.2 (Diesel Generater $uilding) indicates the foundatien of the DG3 to be continueus footings with inde-pendent pedestals for each of the Diesel Generators. Contrary to the structural arrangement described in the TSAR, the settle-ment calculations for the DGB vere performed on the premise that the building and equipment loads would be uniformly distributed l
5 te the foundation =aterial by a 154' x 70' ' foundation zat.
The settlement calculations were performed between August 1976 and Octeber 1976 by Techtel Geotech Division.
Dis:ussien with the Geotech Engineer vhe perferned the settleeent calculations indicated that he had not been informed of the design change of the foundation until late August 1978 when the excessive settle =ents of the DGB and pedestal became apparent.
t 2.
TSAR Tigure 2.5-47 indicates the load intensity for the OGB to be
.'(
a KST (4000 lbs. per sq. f t.); however, the settlement calculations reviewed indicate a uniform load ef 3 KST (3000 PST). This appears te be a conflict between the TSAR and settlement. calculations.
3.
The settlement calculations for the borated water storage tanks' vare performed assucing a' 54' diameter circular foundation mat with an assumed uniferm load of 2500 PST. Instead, the tanks 4
are supported on a continuous circular spread footing and compacted i
structural backfill as detailed on the construction drawings. The Geotech engineer was also not made aware of the revised foundation detail.
TSAR Tigure 2.5-48 (Estiested Ultimate Settlements) indicates the
~
anticipated ultimate settlement for Unit 1 and 2 plant structures. The values indicated for the Diesel Generator Building and Borated Water Storage Tanks are the values developed assuming uniformly distributed loads founded on mat foundations as was indicated in the settlement i
calculations reviewed even thaugh the actual design and construction utilizes spread fo,otings. The TSAR does not indicate the foundation 1
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.m tions and'the e M e the values in l
type assumed in the settlenent c'al'euia.
the TSAR figure appear to represent the settlements estimated fer the s
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as-constructed spread footing foundation.
l 4.
During a review of the settlement calculations, it was observed that the compression index (C for the compacted fill between elevations 603 and 634 in the#)lant area was assumed p
I (estimate based on experience). TSAR Section 2.5.4.10.3.3 (Soil Parameters) indicates the soil compressibility parameters used.in the settlement calculation are presented in Table 2.5-16.
This table indicates that for the plant fill elevations 603 te.
63', the compression index used was 0.003. Contrary to the ySAF.
value. 0.001 was used in the settlement calculations reviewed.
3 This value is directly used to deternine the estimated ultimate s,ettlement of structure supported by plant fill material.
Based on the above exaeples, ressures did not assure that soecific
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design bases, included in design documents, vere translated inte the
'g.
license application resulting in inconsistencies between design docu-
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ments and the FSAR. This is considered an itse of nonco:pliance with 10 07R 50, Appendix 3 Criterion til as identified in Appendix A.
(329M S-20-07; 330/75-20-07)
Discussiens with C?Co persennel responsible for the technical revie -
and format indicated that a comparison between the design documents 4
and FSAR had not been performed. 1.ikewise, Bechtel personnel indi-
_E cated that a detailed comparison for the technical accuracy of design 4[
documents te the 75AK statements had not been performed; instead
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reliance was placed on the originator's input.
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foundation According to the Civil Engineering Group Supervisor, a cat All was considered for the DGB only during the conceptual stage.
drawings generated show a spread footing foundation..The supervisor stated that the Geotech engineer apparently based his calculations on the conceptual stage information. He went on to say that an individual.
in Geotech was responsible for checking the calculations and the first thing he is supposed to do is determine that the basis for the calcu-He said that apparently this was not done..
lations ia correct.
e Review of Settlement of Administration Building Footinas During the investigation, it was disclosed that the Administration Building at the Midland Site had experienced excessive settlement of the foundation footings. Although the Administration Building is a non-safety-related structure,-it is supported by plant area fill material compacted and tested to the same requirements as saterial i
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r to the supporting safety-related structures and therefore pertinent settlements being experienced by the Diesel Generator Building.
current f
The following are the events relating to the settlement of the Ad ind-s,tration Building footings.
During the end of August,1977, a Bechtel field engineer 'oserved a gap On between a slab and the grade beam of the Administration building.
August 23, 1977, a survey was taken of the settlement. The results indicated that the foctings supporting the grade beam had experienced settlement ranging frc: 1.32". (north side) to 3.48" (south side).
This settlement took plate between July 1977, and the end of August 1977. The footings were supperted by "rande: fill" (Zone 1 saterial..
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The concrete footings on the order of 7' 6" by 7' 6" by l' 9" deep The random fill r.aterial was were reesved along with the grade beam.
According to C. 5. Testing personnel, it was observed also recoved.
during excavation of the fill material that there were voids of 1/4" l,
to 2" or 3" within the fill and these were associated with large lumps cf unbroken clay measuring up te 3 feet in diameter.
e The Civil Tield Engineer assigned responsibility for plant fill work i.
said that, although he was no soils expert, it was his opinion that the proble= vas caused by the presence of pockets of water due to drainage frc: the steam tunnel. The Lead Civil yield Engineer also indicated e'
5 a drainage proble: caused the Administratien Building footings _ settle-f They were, however, unclear as to how the water pockets were eent.
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fermed, i.e. whether they were ferred as the fill was being placed or
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hev they could devele; af ter the fill was co:pacted.
The excavated fill was rcplaced with concrete and the design of individual foetings was changed to a continuous spread footing I-design for support of the building.
j As a result of the settle =ent of the ' Administration Buildin stration Building araa, one in the Evaporator Building area and one south of the Diesel-Ggnerator Building. In the Administration Building
! area the foundation material was found to be " soft" with " spongy char-
' acteristics." The rvo other borings did not indicate unusual material 5
These borings were i
! properties in that the blos counts were reasonable.
- taken in September 1977.
The licensee indicated that reports from Bechtel concluded that the primary cause of the settlement in the Administration Building aren was insufficient compaction of,the fill. Bechtel also concluded that i
" deviations from specific compaction requirements was the result of k.
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- 3. R gU repeated erroneous selection of 'ckm/ action schn'dErd,N*.e. the ine:
i eptimum moisture-density curve was used for the soil s'aterial being I
compacted. In effect, the moisture-density curve was. erroneously assu ed the soil being used and therefore soil was compacted to 4ss l
tp represent than maximum density.
1 Bechtel personnel including the Civil Group Supervisor, Project Engineering, the Tield Project Engineer, the Lead Civil Tield Tagineer, j
and the Chief Civil QC Inspector, all stated that the Administratic:
The Building footing settlecent was regarded as a localized oroble.
question as to the adequacy of the entire plant area fill did net a:rfse eten though the fellowing similarities ' existed between the Adeinistratien
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Building area and rest ef plant fill; {a) same soil specification artlied.
(2) same material (random fill) was used and (3) same control procedures The Diesel
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and selection of laboratory compaction standards was used.
Generator Building area required even more fill than other safety-related i
structures since its base is located at~a higher elevation than the
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ethers.
Reviev ef Interf ace 3etween Diesel Generator Buf1 ding Teundation and I.
C e-rical Duct Banks I.
A review of the design interface between the electrical and civil secticns cf the Bechtel crgani:atien was performed to determine whether the
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design acceunted for the inte'raction of the electrical duct banks and
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spread feotings on the differential settlement of the northside of the
- D DG3. It was determined that the electrical and civil groups made "I
a:ce==edations in the design tc permit settlement of the spread fe tings areund the electrical duct banks by including a styrofoas " bond breaker"
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areund the duct banks. Beth electrical and civil groups reviewed and approved electrical Draving E-502 which includes the appropriate detail.
I However, Bechtel Draving C-45 which 1.dentifies class I fill material -
g arcas per=its the use of Zone 2 (random fill) which' includes "any material free of humus, organic or other deleterious raterial." This, i
in effect, does not preclude the use of concrete arosnd the electrical duct banks beneath the spread footings. Due to the difficulty in cor-r pacting, Bechtel elected to replace the soil material with concrete, Letter from project engineering to field construction, dated Decerber 27..,
j 1971., states, " lean concrete backfill is considered acceptable for replacement of Zone 1 and 2."
The instruction is considered inadequate, in that, the concrete placed around the duct banks restricted the settlement on the north side of the DGB where electrical' duct banks l
enter through the footing. This contributed.to the excessive differ-ential settlement in the T. ort 5 South direction across the building. -
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This failure to prescribe adequate instructions for activities affecting the quality of safety-related structures is considered an item of cencer-s
(
pliance with 10 CTR.50 Appendix B, Criterion V as identified in A;pendir At (329/78-20-07; 330/78-20-07)
Review of Soils placement and Inspection Activities for Plant Area Till A subcontractor, Canonie Construction Company, South Raven, Michigan, performed the major portion of tht earthwork at the Midland site.
Although Canonie was primarily engaged to construct the cooling pond dike, they also performed most of the plant area fill work. Bechtel, however, also performed plant fill work prior to and after Cancnie left the site in mid-October 1977. The last Canonie daily QA/QC fill placement report is dated October 16, 1977.
According to Canonia QA/QC records the first fill in the DCB area was
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placed in late October and early November 1975. No further fill was
,b placed in the area until July 1976. After that time, fill work in the area was interspersed with soils work in other areas.
I While it would be difficult to identify the soil work performed by Sechtel versus that performed by Canonie, records reviewed indicated that most cf the Bechtel work was done during the latter part of 19,76 and continued through 1977 and 1978. Although cost of the 3echtel verk
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related to placing sand around piping and ducts after they were laid and placing sand adjacent to valls, some motorized work compacting clay fill was also done by Bechtel.
"['
Regarding the plant fill work performed by Bechtel, CPCo Audit Report No. T-77-21 dated June 10, 1977, identified a number of deficiencies vhich recommended the corrective action to be as follows:
(1) "the foremen directing the soils work should be instructed as to the required moisture content limits" and (2) "the foreman directing the s
soils work should be instructed as to the correct rest frequency requirements." Interviews with two such Bechtel foremen confirmed the fact that they were directing soil operations. They indicated they received their instruction regarding lif t thicknesses and testing requirements verbally from field engineering through a general forer.an.
I Bechtel design criteria C-501 (Page 8) and PSAR Amendment No. 3 (tames-and Moore Report, Page 16) states that, " Tilling operations should be performed under the continuous technical supervision of a qualified soils engineer who would perform in-place density tests in the coepacted fill to verify that all materials are placed and compacted in accordance with the recommended criteria."
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(N.jm.=n Based on the above, the'scils actfvii:ies were n'of Ec~ddslished under the p
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continuous technical supervision 1'n accordance with Bechtel design crf-This failure to provide a qualified soils engineer to perfere
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teria.
t.echnical supervision for activities affecting quality as required by,*
spe:ifications and the PSAR is considered an item of noncompliance vit i 10 CFR 50, Appendix B, Criterion V.
(329/7F-20-08; 330/78-20-08)
The foremen indicated that Bechtel Field Engineers and QC inspectors were The fort-en rarely in the areas where soils activities were going on.
decided vben and where tests were taken. The locations of tests vere approximated by pacing or visually estimating distances from ecluens 1.if t thicknesses were detetr.ined visually, usually or building valls.
I sithcut the use of grade stakes.
Soils testing services are provided by U. S. Testing Company based on the requirements of Specification C-208.
The two U. S. Testing tech-nicians who said they performed an estimated 90* of the soil testing during the years 1975-77 indicated that they rarely saw a Bechtel field
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fill activities were engineer or QC inspector in the areas where plant One technician said he could recall only one occasion when going on.
The a QC inspector was present when he took an in-place density test.
T.
ether technician estimated he had contact with a QC inspector in the field about once a month. A Bechtel QC inspector, however, was ass,igned s
to the testing laboratory on a full-time basis.
2' I
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U.S. Testing persennel stated that erroneous test locations were p chronic proble: regarding the Bechtel placed fill.
rhe location of
?g a test was usually given at the time of the test by a labor foreman or a laborer if the foreman wasn't there. Someti=es, however, a fors=an
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was not. familiar with the area in which he was working and the locatien It became necessary 'en
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was not provided until sometime after the test.
f location.
occasion to withheld test results as a means of getting the test elevations were approximated sequentially.
i Test s,
The technicians further advised that rarely did a Bechtel OC inspector Normally, labor foressa r.equested them. On occasion i
request a test.
a technician passing through an area vould be asked by a foreman if a test should be taken. Upon completion of in-place tests.the results Test were usually communicated to the foreman directing the work.
A failures were also reported by telephone to QC or Field Engineering.
Engineering veekly report of test was provided to Bechtel QC and Tield who reviewed any test failures and resolved them.
U. S. Testing personnel advised that they were requested to take tests of clay fill while it was raining and in order to do so, plastic was held over them to protect their equipment while the test was made.
Even though it was raining, the fill placement work was not stopped on S.
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some occasions. A Bechtel foreman confirmed that density tests were on occasion taken while it was raining. While this is not contrary to the
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specificatirn instructions, it is contrary to standard practica.
l t*. 5. Testing personnel indicated that when moisture was added, the procedure did not include blending the material which resulted in mushy seams. It is commonly accepted good paretice to disc the ii:1 af ter spraying it with water to add needed moisture. A Bechtel fereman stated that if moisture was needed they compacted 6" then sprinkled it I
and then added another 6".
The field engineer whe was assigned responsibility for plant fill vhrk stated he did net spend full time on soils work since he also had responsibility for two structures, the steam tunnel and general yard vork. He said he tried to get out to the area where fi,11 work was being'done once a da..
Some times he did and sometimes he did not.
He indicated it was his impression that the QC Inspector responsible for the soils work on the day shift visited those work areas once or twice a week. He confirmed that only oral instructions were furnished to the fere=en when he felt were conscientious. The main problem he experienced with'the fore =an was maintaining proper lif t thickness.
The QC inspector who was primarily responsible for the plant fill work s'
is no longer a:plcyed by Bechtel. The QC inspector who was responsible I.
for.the plant fill work on the night shift stated that he tried te devete about one hour a ni5 t to the plant fill activities. He indicate,d that h
c during 1976-1977 there was much emphasis being placed on cadwelding and
-(
rebar work and it was necessary te spend the majority of his time on those activities. He maintained that he did have fairly frequent contacts vich the technicians who performed the in-place density tests, partic-ularly when test failures occurred. He indicated it was his impression i
that the labor forecen were directing fill placement adequately.
Review of Inseection Procedures The following procedures which are relative to backfill operations t ' '.
at Midland t' nits 1 and 2 between August 197I. through December 1977 were reviewed.
I Bechtel Master Project QC Instruction for Compacted Beckfill -
i 2
a.
C-1.02 was issued for construction October 18, 1976,.and it is presently the current instruction which is.used by Bechtel QC l
i (when Bechtel is the inspection agency, providing first level inspections during backfill operations). Further, this instruc-tion was used by Bechtel-QC when monitoring the activi,.ies of 6
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Y; other inspection agencies (Canonie) when such age'ikies were 1
perforr.ing the first level inspections of backfill operations e
1 during che time periods of October i8,1976, until June 28, 1977.
I h.
Bechtel Quality Control Master Inspection plan for Plant Founda:I:n Excavation and Cooling Pond Dikes (Plant Area Backfill and Bet
. Backfill) - Procedure No. C-210-4 was the instruction utilized by Bechtel QC when monitoring the activities of other inspection agencies that were providing the first level inspections of b=:k-fill. operations (this instruction was utilized during time periods prior to October 18, 1976).
.i c.
Bechtel cuality Control Master Inspection Plan for Structural Backfill Place =ent - No. C-211-1 is an instruction utilized by Bechtel QC when perfor=ing first level inspection of backfill activities prior to October 18, 1976.
s t1 Bechtel Procedure C-1.02, listed above, was written as a replacement for both Procedures C-210-4 and C-211-1.
The inspection activities which were delineated in Precedures C-210-4 and C-211-1 were esapared with those described in Procedure C-1.02.
The following are some of those activities which were compared:
I Inspection Code for-
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Activities / Task Descriftfon C-210-4 C-211-1 C-1.02 y.
'1 Backfill Material l*
(*)
1.
Free of brush, roots, sod, I
S(V)
- [
snow, ice er frozen soil.
(*)
2.
Material moisture conditioned S
I 5(V) to required moisture' content.
3.
Structural backfill used I
with 3" of plant structure.
shall be cohesionless and f ree-draining.
.(
(*)
4.
Material not placed upon I
$(V) frozen surface.
I..
5.
Foundation approved prior to H
H R/E backfill placement.
6.
Prior to start of work, area I(v) free of debris, trash and unsuitable material.
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Cor.caction Requirements
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1.
Cohesionless material com-S S
S(V) pacted not less than 50 relative density.
(*)*, 2.
Cohesive material compacted '
W S(V) to not less than 95 max.
density.
(*)
3.
Zones 1. IA, 2 and 3 nacerial W
I 5(V) in uncompacted lifts not ex.
ceeding 12"; areas not access-ible to roller equipment the material placed in uncempacted lif ts no exceeding '".
,4 Material Testine 1.
Verify testing and test results are as'per engineering requirements.
a.
Materials S
S S (.V) i 5
S 5(V)
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b.
Moisture 1-c.
Cc=paction S
S S(v) 2.
Reviev lab test report verifying:
9.
Proper test method.
R R
R a.
b.
Proper test frequency.
R R
R c.
Technical adequacy.
R R
R I - Inspection point H - Hold point W - Witness point S - Surveillance (V) - visual R - Review records Those activities identified by an (*) asterisk indicate ' inspection require-ments which have been relaxed from the original procedural requirements.
It is considered that the relaxation of actions relating to the confir-nation that soils ' placement activities were conducted according t'a O
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ction Ef ' testing, alitE N*5-c f, ^%" "'
compa from inadequatede iation'sfreque ny c
qu affe ting Criterier.
v ofontrol and c
contribated to nce of a tivities50, Appendix B, cide
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crease iness, m istu ection 10 c
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eciff nd the inthickn CFR adequ te in p with 1,,
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a ce co plian agarding re to pro ideed an item /78-20-09) m of n chtel 4-v on esent
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Coepa y and Be23,1979 to pr f ailu EQ' 09; 330 n
That ibis si er 0
d wer vestigation.
fs.(392/76 2 -
ers Po con 5,
g n Februaryof the in held on P.archhe preliminary um Cons X.
with ie o Region III of f cfindings s
vere cond eeetingesponded to,t eetings 15, 1979 Meet nie ff eet of the NRC sta Exit ary se m
March the SRand ; r eliminwed by aCo pany r during thesedated C
Members at follo m
sed letter n
e ratio ently ers Po nts NRC wer u
Co po cepe, purpos, subs quCons r
enme e
um by The dower Compa y s
n the was which e ting ring findings.ers Po e
m 1979, duvestigationd to Con sum intran :-itte s
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[pMb Augus 21, 1910 Ms. Barbara Stamirisr 5795 North River Road Freeland, Michigan 48623
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In the Matter of l
CONSUMERS POWER COMPANY (Midland Plant, Units 1 and 2) 2 Docket Nos. 50-329 & 50-330 OM & OL
Dear Ms. Stamiris:
P Per your request of Messrs. Wil11am Paton and Darl Hood of the NRC last week, enclosed p1 ease find copies of the nonconfomance reports and the quality action requests referenced in paragraph 4 in Appendix A of the December 6, 1979 Order Modifyine Construction Permits for the Midland plant. The two related audit reports you, mentioned are also enclosed.
51ncere1y, I
Steven C. Goldberg Counsel for NRC Staff
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Enc 1osures:
3 Action Request No. 3D40 Nonconformcnce Repdrt Mos. QF-29, QF-52, QF-68, QF-120, QF-130 QF-147,QF-172,QF-174,QF-199,QF-203 AuditPeportNos.77-21and77-/2 cc w/ enc.:
Frank J. Kelley, Esq.
Internal Distribution:-
Myron M. Cherry, Esq.
MRC Central Ms. Mary Sinclair OELD-FF(2)
Michael I. Miller Esq.
Shapar/Enaelhardt Grant J. Merritt, Esq.
Christenbury/Scinto Judd L. Bacon, Esq.
Olmstead/Karman Mr. Steve Gadler Paton/Chron(2)
Wendell H. Marshall Goldberg/Chron Michael A. Race Jones Ms. Sandra D. Reist D. Hood -116-C Ms. Sharon X. Warren IJLee - 147 Patrick A. Race George C. Wilson, Sr.
Ms. Carol Gilbert William A. Thibodeau l
Terry R. Miller g
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'.. e Section 13.0 of saeciftettfon 7220-C-210, Rev. 4 orevides the s
Q-listed backfill in the plant area.
Saction 13.5 statas that the cofsture in this area shall be in accordance with Section 12~.6 ecific' anon.
Ssetion 12.6 states in part:
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."Tha water contant during.c:m;: action shall.not be.
rnere than-2 cereentace cofnts'below cottmum reisture conterit
....g more than 2 perce:ttage points'a'bove'opitimum maist i.9; "'I '. '....N.".% I 4
"Tatts done in adeerd=nce with cars.12.5 will indicat tNd
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!c rate *fel nn the_ err %nleaent fili. the mots'ture ce tant sha er ad sted 8%=w':g j g yas.:.n=e.essaz
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for compaction."
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=?.olling of any section of embankment containing material too wet or too dry to obtain the required compaction shall be delayed until the r,of 5tura contant of the caterial is brought to within the required limits or t
the material shall be removed and replaced with sditable material..."
..z Contrary to the above: [The field does not take moisture control tests prior to and during placement iff the backfill, but rather rely on the moisture results taken from the in-place soil density tests.
l Racert: ended Corrective Action
- 1) A system for tes' ting the soil for moisture content prior to' comp' action should be developed and.1=plemented by Bechtal and 'the subcontracy.or. QC should make any necessary revisions to the QCI.
- 2) Recognizing that the soil has been tested for moisture. content after compaction and meets the requirements of the specification it is not necessary to identify these ' materials as nonconfaming. However Project Engineering should be apprized of the past testing methods. In addition it is rec =rnended-that ergineering concur with-the-intarpretation-that moisture contents taken after compaction are for detamining dry densities and should not be used for specified coisture control.
- 3) Assure respensible p:ersonnel are aware. of the testing system.
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odtober 14; 1974
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, N?nconformance Uo 0F29 Quality Control This Honconformance Repor^. is Issue.d to:
Prepared By 'h.;Uf,f,1,Mata i > p/.-N Mr.".i.PCConno[1
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cviewed By
'E "[4.6 Data f?'4 7/-* 5 7
Bechtel', Project Fic1d Quality Control Ent:ineer Written Re ly Require.d,,By Date 10-24-N-I Action Required By Date If-14-74 l who is responsible for' correction action.
Nonconfor=auce Description an6. Supporting Details:
Specification C-211 Rev. O and SCN No.. Q-211-4001, 5.6.2 states "Ifacerial delivered to the jobsite for u'se as structural bukfill. shall be. vim 11v inspeceed, and tested in accordance.with ASTM C-117 and C-136 bd the contractor' r.4presentative de per damn material is being delivered."
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Structural backfill caterial was'dalivercd bn thirty -(30), days. in ' August and September, but the,.
'. QC Pile only has test reports for one (1) of the thirty (30) days.
U.S. Testing File only
' has test reports for eleven (11) of the thirty (30) days.
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.EC Reportable Yes O ' no 0. see 7:eeedure 9 - aetortins or nericiencies to Arc -
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..AEC Notified on By Method
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- 7. 5eco=aended Corrective Action -(If Appropric.te):
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(1) Evaluate the structural b'ackfill I
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" aterial in place and in the stockpile with additions 1~ tests.
(2) Locate the missing test, Q) Cerrect the problets of U.S. Testing pot being notified of.,in coming structural c eper't s. -
backfill caterial.
Corr 4ctive Acticr. To'3e Taken: (( ) Eva uzte the st:r'uctural backfil'1 ma.terial in the
. stockpile.with additional tests.
(2) Locate the raissing test reports. (3) Correct the.
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problem o( U".S. Te' ting not being ', notified of. ihcoming structura'l backfill material.
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.3 h.2derlyin-Cause of Roaconforcesce:- The underlying 'ceds' 'of this nonconfoh c
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- t. Bechtel Qus11ty Coittrol.'wat not being fully informed of materil.l deliveries, therefore
c U.S. Testing was not being luformed bycBechtel Quality Control.
e (CorrectiveActionImplement;c and Nonconformesce Closed) Ccnfirmed By d'd s. ' e (L) Bechtcl"NCR 198 was initiated.
- 26. additional samples Date 6.feru.<n.u I.'..#1 6 war {. tuken f, rom the ' tockpile. 8echtal Project Engineering's Disposition is tb "use as is"l s
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Ta 51 on tho'rcsults of the additional samples.
(
, necdtin.the QC File (3) A memorandum from E. E. Felton directing that Quality Cont stif Ltd of alLincoming shipnents of structural backfill material was issued on October 29c Q 374.
2To De Provided by Addressee.
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d*Rei.4ued January 19, 1976
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.FMSouthworth SHHowstil Issue Date Aunust 7. 1975**
HWSlager CSKeeley (2)
Project m attind 1 &7 CQHills TCCooke COnsum8f5 POWar File Title NCR's on Bechtel Qualit-JM11andin WFHolub C# " * " I
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Nonconfomance CLRichardson
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Report No QF-52 e.,%
m-mis Nonconformance.Jteport is Issued'2b:
Prepared ByDdd'Ms% Date B F ~7f l Mr. J. P. Connolly Bechtel Project Field Quality Control Written Reply Reques By Date 9-s-75 D
Engineer Corrective Action Requested By Date 9-5-75 wha is responsible for corrective actf on.
Nonconformance Description and Supporting Details: (1) Specification C-210 Rev. 4 g
Section 13.6 for plant area backfill and bara backfill states " Moisture control of the plant area and berm materials shall conform to section 12.6".
Under section 12.6, 12.6.1 states in part that "the water content durine compaction shall not be more than two percentage points below optimum moisture content and shall not be more than two percentage points above optimum moisture content".
Contrary to this requirement, test no. MD202 for plant area fill located 14' east of 8.7 line and 36' north of A line at elevation 594.5 had a moisture content 2.9 below optimum moisture content.
Approximately 7 feet of material has been placed over this failing material.
(Contd)
AEC Reportable Yes No x See Procedure 9 (For Nuclear Projects Only)
Stop Work Necessary Yes O No x See Procedure 16 - Stop sofk No Reco:mnended Corrective Action:
(1) Receive a Proj ect Engineering evaluation on the acceptability of the material in question or remove the material.
(2)
U.S. Testing should have training sessions to take corrective Action to preclude repetition.
(3) Quality Control should have training ' sessions to take corrective action to preclude repetition. The written replies to these items is requested with the Project Engineering evaluation.,
1Corrective Action Taken:
(1) Project Engineering has evaluated and accepted the in M
place material with low moisture contan* h eed on a satisfactory compaction test result.,
(2) United Scales Testing und Bechtel Quality Control have sach had training sessions
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re-emphasizing the acceptance criteria for ' soil tests.
1Verification of Corrective Action Required-Yes @ No O.
hthodofVerification:
Reviewed Bechtel NCR #324 covering item (1) of this NCR '(QF-52)'
and the Project Engineering disposition. Also reviewed letter FQCL-049 dated 8-13-75* t that states U.S. Testing and Bechtel Quality Control have each had training sessions -
to re-emphasize the acceptance criteria for soil tests.
1
%1 Mf.9Lw Nonconformance closure Confi med By 1
.Date S-f 4 7f f
i 1To be completed at time of closure by Consumers Power QA Services.
Page 1 of 2-
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File Title NCR's on Bechtel Quality
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Control i
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Nonconformance Report No QF-52 (Contd) 4 Nor.conformance Desebption and Suppo'rting Details:
(Contd)
,we (2)
This failing test was shown on the compacted fill density test report form QC-C1 as passing by U.S. Testing in the remarks. column.
(3)
On the back of the QC-C1 form, in the FIM, it states the entry information.
.For Block no. 3 the entry information states "to be signed and dated by the QC Edtineer signifying the form has been reviewed for completeness and correctness".
Contrary to this requirement, the Quality Control Engineer had signed on the compac fill density test report the acceptance of ND202 which had actually failed.
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. SH_Howell
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CQuills TCCooke Ontur*'1 POWtf.
File Title. ftCR's on Bechtel JMilandin 1
0"9 if? P "l M WFHolub Noncen.ormance l
CLRichardson Report No Of-68 Subinet File This Nonconformance Report is Issued'To:
Prepared By9J'@.4 c/h, Date /O-t L. 75 Approved By!M t'd-J<~
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Written Rep 17 Requeste M.
Date *-
J. P. Connolly y Date 11-17-7 Bechtel Project Field Quality Control Engineer Corrective Action Requested By Date 11-17-3 who is responsible for corrective action.
Nonconformance Description and Supporting Details: Specification C-210 Revision 4, section 13.7 states in part "All backfill in the plant area and the berm shall be compacted to not less than 95 percent of maximum density as determined by modified Proctor method..."
Contrary to this requirement, the compaction test MD142 taken in the West Plant Dike had been calculated using the wrong maximum laboratory dry density for Bechtel Modified Proctor, resulting in a.96% compaction which is passing. Using the correct maximum ' laboratory dry density results in 92% compae-tion which is failing.
AEC Reportable Yes O No See Proe-e:re 9 (ror Nuclear Pro 3ects on17)
Stop Work Necessary Yes No X See Procedure 16 - Stop Work No Reco::nnended Corrective Action:
See Attac}snent A.
Corrective Action Taken:
See Attachment A.
Verification of Corrective Action Required Yes No O b4ethodofVerification:
(1) Compared 17 Bechtel Modified Proctors to Field Work Sheets. (2) Reviewed revised reports for correctness.
(3) Reviewed U.S. Testing's system for checking tests against a Master Proctor List and a Master 1.og Book.
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b onconformance Closure Confirmed By b d S. M r'
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-4 Date Ii-7 I 75 y
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1Tb be completed at time of closure by Consumers Power QA Services.
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Pile Title NCR's on Bechtel Quality Control I
r Attachment A
. Nonconforinance Reporl No QF-68 N
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Reconnended Corrective Action I
(1) Review all Bechtel Modified Proctors (BMP) and Field Work Sheets used by U.S. Testing to assure the maximum laboratory dry densities and optimum moisture contents on the BMP's agree with the Field Work Sheets.
(27 If there is a discrepancy between the maximum laboratory dry densities and/or the optimum moisture contents, review all compacted Fill Density Test Reperts that used the maximum laboratory dry densities and/or optimum moisture contents in error.
(3) Resubmit all test reports that used the==vinum laboratory dry densities and/or optimum moisture contents in error.
(4) Receive a Project Engineering evaluation on the acceptability of the failing test MD142 and any f ailing tests that are found during the review.
~
(5) Take corrective action to preclude these occurrences.
The written reply to these items is requested with the Project Engineering evaluation.
g-Corrective Action Taken:
(1) A complete comparison of all Bechtel Modified Proctors to Field Work Sheets was performed by. United States Testing.
(2) Three additional discrepancies were found during this review. ~ A total of twelve Field Tests were affected by the discrepancies.
(3) Revised reports have been submitted for the twelve Field Tests.
l (4) Failing test MD152 has been cleared by passing test MD160. None of the twelve Field Tests were found failing after corrections had been made. A Project Engineering evaluation was not necessary.
-(5)
U.S. Testins has devised a system for checking tests against a Master Proctor List and a Master Los Book.
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~ FMSouthworch-- SHHowell Issue Date,.7 Secte nber 71. lo76
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HWSlager CSKeeley Project
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CQHills TCCooke
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M NN File Title' kCR'sonBechcel
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JM11andin constructi5n & Quality Control JMKlackin8' Nonconformance CLRichardson Report No QF-120 Subiec't File
'Ihis Nonconformance. Report is Issued To:
Prepared Byh.d.C.h Date 9.-2f1"fd J. P. Connolly Approved By M.2? f ~"
Date 9-X 'M Bechtel Project Field Quality Control f
Written Reply Requested By Date in.n_7 Engineer J. F. Newgen Corrective Action Requested By Date 10-8-F Bechtel Project Superintendent who is restonsible for corrective action.
orting Details:
Specification C-210 Revision 4 Nonconformance Descri tion and S 12.5.2,12.[.3 and 12.5 state in part that (1) The uncompacted lif t thicknq sections of soil placement shall be not more than 12 inches.
(2) In areas not accessible to roller equipment, the material shall be placed in lifts not to exceed 4 inches in uncompacted thickness. Contrary to these requirements, (1) soil was placed between manhole #5 and #6 above the Sanitary Sever in the West Plant Dike in an uncompacted lif t thickness varying between 9 and 14 inches, (2) in an area not accessible to roller equipment, soil vas placed between manhole #4 and #5 above the Sanitary Sewer in the West Plant Dike in uncompacted lift thickness of 6 inches. The material was removed down to the required lift thicknesses and compacted, prior to continued work in this area.
AEC Reportable Yes No @ See Procedure 9 (For Nuclear Projects only)
Stop Work Necessary Yes O No G see Procedure 16 - stoP wors No
~
No Hold Tags Applied.
Reccanended Corrective Action:
(1) Detsrmine why the original uncompacted lift thicknesses exceeded the maximum lift thicknesses.
(2) Takn corrective action to preclude repetition.
1 i
Corrective Action Taken:
(1) This was the result of insufficient monitoring of the placing crews and the work was donc in accordance to the note on Detail 6 of Drawing C-130, Rev. 3 which in confilet with Specification C-210.
(2) A Trni"4"- % - " a" "" eiven en the 1nborer General Foreman and 1.aborer Foreman!
7 and DravtNe Change Notice No. 5 to Drawing C-130, Rev. 3 corrected the conflict Verification of Corrective ' Action Requirekecifi between Drawing C-130 Rev. 3 and S ion
!10.
Yes No I
l iMethod of Verification:
Reviewed Trnining Session BT94, letters BCCC-2068 and FQCL-114, and DCN No. 5 on Drawing C-130, Rev. 3.
~
konconformancoClosurnConfirmedDy 8.b '
Date' II -J G
.y 1To be completed at time of closure by Consumers Power QA Services.
Page 1 of 1
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BW!arguglio SHitowell l
1ssue Date Octooer 16 19M
',., / 'T CSKeeley Project
.}idland162 HUSlager C
e f1 Jmtaclaren g
JMKlacking Nonconformsice Ouamy pong 1-har Report No 0F-130 c
mis Nenconfomance Report in Issued To:
Prepared By 3d 6.')k Date lo - f G-_~78 A p mved By S S M # Dah MN P
J. F. Connolly WrittenRe'plyReques,teIByDate Bechtel Project Field Quality 11-1-76 !
Control Engineer Corrective Action Requested By Date 11_a_7r, who is resconsible for corrective action.*
Uonconfomance Description and Supporting Details:
Field Inspection Plan C-210-4-55 Rev. O for Placing Plant Area Backfill, North of "A" line, "4.55" to "8.7" line, elevation 610' i to 634.5, under section 2.20 Activity /
Task for " Placement" item i states " Zone 1,1A, 2 and 3 material placed in uncompacted lifts not exceeding 12 inches. Areas not_aecessible to roller ecuipment, the material ged in uncompacted lif ts noeWeeding 4 inches".
Contrary to this Activity / Task, Quality Control Engineers have observed material placed in approximate 12 inch uncompacted lif ts where roller equipment was not used to compact the material.
AEC Reportable Yes O No @ See Procedure 9 (For Nuclear Projects 'Only)
Stop Work Necessary Ye's O No G See Procedure 16 - Stop Work No No Hold Tags Applied Recommended Corrective Action:
(1) Review other C-210-4 Field Inspection Plans for simila,r problems.
(2) Determine the cause of the nonconformance above and similar problems in (1) above, if any found.
(3) Take corrective action to prec.lude repetition.
1Corrective Action Taken:
(1) All closed C-210-4 Field Inspection Plans have been reviewed and similar situa-tions as described in QF-130 existed (i.e., that 12 inch lif ts were placed in areas where roller equipment was not used).
(2) Cause of nonconfomance was misinterpretation of specification requirements.
(3) To preclude. repetition QCI C-1.02 vill be used to inspect compacted backfill and la training / discussion session was held on 2/2' 7.
Verification of Corrective Action Required Yes No Method of Verification:
Reviewed letter FQCL-142.
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I E-Nonconformance Closure Confimed By Date '. W 1To be co:;pleted at ti=e of closure by Consumers Power QA Services.
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- EWlarguglio SFliowell Issue Date( february 2.1977)
HUSlager GSKeeley Project
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r, TCCooke h$r JMilandin COntuntu POWN File Ts.tle ica'sonBechtet JMKlacking Construction and Rechre) Quality CLRichardson Nonconformance Control Subje'et File Report No QF-147 Dsis Eonconformance-Report is Issued *1b:
Prepared By b,JJ8 h%Date.'l
.~1
~77
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Mr. J. F. Newgen g 7,; gy,M d... ( - r Date N N 2 j
Bechtel Project Superintendent e
Written Reply Requested By Date 2-14-77 Mr. J. P. Connolly Bechtel Project Field Quality Control Corrective Action Requested B7 Date 3-15-77 Engineer who is resconsible for corrective action.*
Nonconformance Description and Suppozt.ing Details: (1) Specification C-211 Revision 3 j/l section 5.6.2 states " Material delivered to the jobsite for use as structural backfill
.N ' /
I g INg1 shall be visually inspected, and tested in accordance with ASTM C-136 (and C-117 when s
required by the Field Engineer) by the Contractor's representative once per day when material is being delivered".
(2) Project QC Instruction No. 7220/C-1.02 Compacted Backfill Revision 0 section 2.3 D states in part "The following tests shall be taken at the specified frequencies:
4.
During each day's delivery of structural backfill material, a minimum of one representative sample tested in accordance with ASTM C-136 (and ASTM C-117 as determined by Field Engineering) to the gradation requirements specified, prior to placement".
(Contd)
AEC Reportable,Yes No @ See Procedure 9 (For Nuclear Projects'Only)
No C See Procedure 16 - Stop Wor.k No Step Work Necessary Yes Bechtel applied hold tags to the structural backfill, stockpile.
Recoc: mended Corrective Action:
See attachment.
lCorre,ctive Action Taken:
See attachment.
1Verification of Corrective Action Required Yes X No Method of. Verification:
Verified review of structura2 backfill deliveries for October and November,1976 i
for lack of testing on Februsry 9,1977. Reviewed letters FQCL-140 and BCCC-2373 Training Filo BT-il7 and NCP.'s 686 and 698, konconfomance Closure Cor. fined By kM b.Nb f
!.x; Date 6 - (0
? "7 lb be cos:pleted at time of closure by consumers Power QA Services.
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Issue Dace February 2, 1977
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Project Midland 1 & 2 r
File Title NCR's on Bechtel Construction and Bechtel Quality Control 1
,, Attachment to Report.No QF-147
. =. ; -
Nonconformance DesEription and Supporting Details (Contd)
Contrary to (1) and. (2) above, structural backfill delivered on December 1,1976, December 14, 1976 and January 11, 1977 was not tested for gradation requirements.
I Rec,ommended Corrective Action:
(1) Review October and November structural backfill delivered in 1976 for similar lack of testing.
(2) Receive a Project Engineering evaluation on the material lacking gradation tests including any found in the review in (1) above.
(3) This same problem of structural backfill material lacking gradation tests was identified in CPCo NCR QF-29 issued October 14, 1974. - The corrective action to preclude repetition for this NCR was a memorandum from the Project Superintendent directing that Quality Control be notified of all incoming shipments of structural backfill material was issued. Recently, Bechtel QA
[,
identified this same proble::t in QADR SD-6 issued October 21, 1976. The cor-rective action to preclude repetition for this QADR was to use the following system:
a) Each day's delivery of structural backfill is stockpiled separately.
b) On the following day the responsible field engineer verifies that the materini was tested and is acceptable.
i c) If the material wasn't tested, a test will be taken at this time or if the material is acceptable, it will be placed in the acceptable pile.
I i
It in evident that the corrective action taken for NCR QF-29 and QADR SD-6' is not adequate.
Determine the underlying cause(s) and propose further corrective action to preclude repetition.
Igorrective Action Take'n:
(1) Shipments of structural backfill delivered in October and November,1976 have baen reviewed. NCR's 686 and 698 have been written identifying the lack of testing in this NCR and in the review of October and November, 1976 delivery tickets.
I i
(2) Project IJugineering has evaluated the materials lacking gradation tests in NCR's 686 and 698 and has dispositioned it "use as is".
.v Page 2 of*3
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,p Construccion and Bechtel Quality Control
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Corrective Action iaken:
(Contd)
(3) Starting Friday, February 4,1977 incoming structural backfill was contr.olled in accordance with the Quality Control Receipt Inspection Program.
In addition, a training session was held on February 10, 1977 on the contrei cf Q-list backfill sand to preclude repetition.
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16.3.4. 16.3.G cecurreil.
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tsa r Issue Date Juiv is, loll f
i.,RSird(Third) 0" Pro,iect Iticiano 1AP OE5kaggs (Second)
BMlarguglio (First) )RJohson Consumers Power File Title nrp * < nn n ent e n
SXee ev Construction 5 Quhlity (,ontrol 3HKlakTng Nonconfornance
[ inn Report No 0FLi72 misNonconforYEnNNhrtisIssuedTo:
Prepared By k. -e EC 1*"w Date 7-S ~7~7 Approved By M D M.. N,Date f#Y77 G. L. Richardson Bechtel Project Field Quality Assurance Writ'tenPIpkRequest
' Date 7-25-7'7 Engineer Corrective Action Req 3efted By Date 8-26-77 who is resnonsible for corrective action.*
~
Nonconfoz.sance Description and Supporting Details:
SEE ATTACHMENT
~
AEC Reportable Yes No @ See Procedure 9 (For Nuclear Projecta 'Only)
Stop Work Necessary Yes No @ See Procedure 16 - Stop Work No "No hold tags applied" Rec:n=nended Corrective Action:
Have Project Engineering evaluate the acceptability of these materials and determine what action is needed to correct these problems if the material is unacceptable.
Corrective Action Taken:
Project Engineering evaluated the nonconforming conditions and determined these materials acceptabic.
Percent compaction for MD 342 in !! orth East Dike was incorrect and has been revised identifying the correct (passing) result.
~
Verification of Corrective Action Required Yes @ No O bethod of Verification:
Reviewed the revised North East Dike test MD 342.10!i R. L. Castleberry to G. L.
Richardson dated 0/31/77. Bechtel QA Letter GLR-9-77-317 CPCo Letter 151FQA77 IOM R. L. Castleberry to G. L. Richardson dated 10/4/77 and Bechtel QA Letter GLR-10-77-390.'
bonconfomance Cicsure Confirmed By c:..<5.-[.'0%w
~
Date 10- *. # - 7 '
To be completed at time of closure by Consumers Power QA Serf.ces.
Page 1 of 2 e
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n Attachment to Report ho QF-172 During a review o7 test reports for partial cooling ponds and dikes turnover, the following were found:
,g Specification C.-J10. Revision 4. Section 13.6 states:
" Moisture control of the plant area and berm material shall conform to Section 12.6.
Section 12.6.1 states in part:
"The water content during compaction shall not be more than 2 percentage points below optimum moisture content..."
Contrary to this requirement, test report MD 359 for the North East Dike Station.
29+00 5'R E Zone 2 9 elevation 622 had moisture content of 2.8 percent below optimum moisture content. This test had been marked P - for pass, when actually the test failed.
Specification C-210, Revision 4. Section 13.7 states in part:
"All backfill in the plant area and berm shall be compacted to not less than 95 per cent of maximum density as deter-mined by modified Proctor method (ASTN 1557, Method D)..."
'2 Contrary to this requirement, test reports for the florth East Dike MD 342 Station 30+00 5 Zone 2 0 elevation 622 had 94.5 percent compactiont MD 354 Station 31+00, 100'R off, sand drain Zone 2 0 elevation 622 had 93.7 percent compaction;'and MD 356 Station 29+00,100'R of%_of sand drain Zone 2 9 elevation 622 had 92.2 percent compaction. Test MD 342 had been marked p -- for pass, when actually the test failed. Tests MD 354 and MD 356 had baen marked F - for fail and accepted by 4 roller passes. The 4 roller l
passes are not the acceptance criteria in this area.
Test MD 342 was taken May 25, 1974 Tests MD 354 and MD 356 were taken May 28 L974, anit Tesc HD 359 was taken May 30, 1974.
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- Reissued July 19, 1977 toindicatetimenonconformanges
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Route Ib This Cc 7 For File 16.3.4 16.1.6
'31rd (Third)
WI.!kirglay Issue Date July 15. 1977
,'.5ka ggs (Second)
Q,0,jton M and 1 & 2 3
elatarguglio (First)
S!!Howell MM8f5 POWtr ~
F1'.e Title NCR's on Bechte]
DRJohnson GSXeeley Construction 6 Ouality control JMKlacking Nonconformance
%3%ME Report No 0P-174 This NonconfomabicMSrt is Issued To:
Prepared By.li.w.M Y"9f.'t.s Date 11'YM "
Approved ByI$ [l/M's ate ~7-IS-7 i C. L. Richardson Bechtel Project Field Quality M tten Reply Requested By te 8-19-.77 Assurance Engineer Corrective Action Requested By Date 9-7-77 who is restensible for corrective action.*
Nonconfomance Description and Supporting Details:
See Attachment.
AEC Reportable Yes No @ See Procedure 9 (For Nuclear Projects 'Only)
Stop Work Necessery Yes O no x seeProcedure16-stoPwors.No~
No hold tags applied Recomended Corrective Action:
Have Project Engineering evaluate the acceptability of these materials and determine what action is needed to correct these, problems if the material is unacceptable.
1Corrective Action Taken:
Project Engineering evaluated the nonconforming' conditions an'd determined these materints acceptabic.
1Verification of Corrective Action Required Yes x No Nethod of Verification:
Revicwed IOM R. L. Castleberry to G. L. Richardson dated 8/31/77, Bechtel QA Lotter CLR-9-77-317, CPCo Letter 151FQA77, IOM R. L. Castleberry to G. L. Richardson dated 10/4/77 and Bechtel QA Letter GLR-10-77-390.
bonconformance Closure Confined By Go hdd.$ U+ 1.v Date
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>7 I
L To bo. completed at timo of closura by Constners Power QA Services.
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NCR's on Declltel Construction and f.j;%D' y.mm.
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" Quality Contsbl
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Attachment to Report No QF-174 i
i Nonconformance Description and Supporting Details During a' review of, test reports for partiil cooling ponds and dikes turnover, the following was found:
4
~
w Specification C-210. Revision 2, Section 12.5.2 states.in part:
" Zone 1 and ; tone 1A material shall be placed in the embankment fill as shown on the Drawings or as required..."
Table 12-1 in this specification states in part:
" Zone 1 Impervious Fill - Not less than 20% passing No. 200 sieve..."
Contrary to these requirements, tests 115 in North Plant Dike and MD 359 and MD 358 in North East Dike had soil classification Zone 1 (BHP 114) which has 5.2% passing No. 200 sieve. Test MD 830 in North East Dike had soil classification Zone 1 (BMP 139) which has 3.4% passing No. 200 sieve.
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WLBarela Issue Date ym.. w 4.
to77 Itafarguglio (first) f $h" y Project m innd 1 & 2 on DATaggart (second) e g
$aking O# I I Nonconformance l
ha,nkSn Report No nF-199 Dis Nonconfor=adce Report is Issued *:b:
Prepered By 9 & S d M k Date //- Y-77 An-,
- By (4YdA Dste ///1s'1y G. L. Richardson Written Redfy Requested'By Date 11-?1 77 Bechtel Lead QAE Corrective Action Requested By Dste 12-15-77 Who is resconsible for cor-ective action.
- Nonconfermance Description and Supporting Details:
See attachment.
AIC Reportable Yes No @ See Procedure 9 (For Nuclear Projects Cnly)
Stop Work,Necessary Yes O no G se. Proced=re 16 - ston erx'uo w'
No Hold Tags Applied Rece==e.'uied Corrective Action:
See attachment.
1Corrective Action Taken:
s Soc attachment.
Verification of Corrective Action Required Tes O no O hAthod of Verification:
i 6
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haconformance closure Confitned By j
Date ITo be.coegleted at time of closure by Consumers Pcwer 9A Services.
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File Title NC Qp
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AttachmenttoNCgQF-199 A
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Nonconformance Deleription and Suppbeting Details-
-?
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Specification C-210, Revision 5 Section 12.6.1 states in part, "The water content i
during compaction shall not be more than 2 percentage points below optimum moisture content and shall not be more than 2 percentage points above moisture content..."
Specification C-210. Revision 5 Section 13.7.1 states, "All cohesive backfill in the plant area and the bara shall be compacted to not less than 95 percent of maximum density as determined by ASTM D 1557, Method D".
Specification C-210 Revision 5 Section 13.7.2 states in part, "All cohesionless backfill in the plant area and the berm shall be compacted to not less than 80 percent of relative density as determined by ASTM D 2049..."
Part 1 l
Contrary to these requirements, the following tests had been passed using incorrect e
testing data. Using the correct testing data, the tests fail.
~
North Plant Dike i
HD 290 (sampled 7-16-74) shows optimum moisture content 11.6.
It should have j
been 9.5.
Using the correct optimum moisture content of 9.5%, the actual moisture content is 2.2% above optimum moisture content.
j HD 360 (sampled 7-31-74) shows optimum moisture content as 21.4.
It should have been 15.2.
This also shows maximum lab dry density as 103.2.
It should have
}
been 115.1. Using the correct optimum moisture content of 15.2%, the actual moisture content is 5.4% above optimum moisture content. Also using the correct maximum lab dry density of 115.1, the correct percent of maximum density is 86.4%.
4 i
HD 377 (sampled 8-6-74) shows optimum moisture content as 18.0.
It should hsve been 15.2.
Ustng the correct optimum moisture content of 15.2%, the actual moisture content is 4.5% above optimum moisture content.
Structural Backfill HDR 621 (sampled 10-14-76) shows minimum dry lab density as 94.2.
It should
, have been 112.2. Using the correct minimum dry lab density of 112.2, the correct percent of relative density is 41.5.
Part 2 Also contrary to these requirements, the following tests had failing results and did not indicate being cleared by passing tests or had been marked passing.
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Issue Date November 4,1977 l
Project Midland 1 & 2 l
File Title NCR's on Bechtel r
{'
Construction and Quality Controi l
l Attachment to NCR_QF-199
.jf' et Nonconformance Description and Supporting Details:
.E~
Part 2 (Contd)
North Plant Dike KD 142 (sampled 5-30-74) shows optimum moisture content 8.0, moisture content
'10.3.
This test failed but it is shown as passing.
HD 143 (sampled 5-30-74) shows optimum moisture content 13.8, moisture content 11.4.
This failed but it is shown as passing.
West Plant Dike HD 227 (sampled 10-6-75) failed moisture but has not been cleared.
Plant Area Fill Moisture Test No.
Date Sampled Compaction Actual Optimum hD 1311 5-03-77 61.6% of Relative Density * -
1326 5-10-77
'18.5%
15.2%
1328 5-10-77 12.2%
15.2%
1412 6-07-77 10.4%
15.2%
Structural Backfill HDR 621 10-14-76 78.0% of Relative Density 671 11-12-76 74.8% of Ralative Density 672 11-23-76 75.4% of Relative Density 685 11-24-76 56.2% of Relative Density 686 11-24-76 70.9% of Relative Density 69L 11-24-76 62.0% of Relative Density i
Recommended Corrective Action:
j 1
(1) Determine if there are passing tests in the same area to clear these failing g ts.
(2) If these failing tests cannot be cleared by passing tests in the same area, present these findings to Bechtel Project Engineering so Project Eng'aeering can determine what additional tests, reviews, etc. are needed to justify the material these tests' represent. Have Project Engineering justify the meterial these failing tests represent.
.d (3) ' Determine the underlying cause(s) and take corrective action to preclude repet Lt ton.
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File Title -NCRls on Bechtel in.
Construction aWQuality Control Attachment to NCR QF-199 (Contd) -
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1 Corrective Actiomiraken:
~
~
Part 1 (1) Bechtel QC has determined that none of the above failing tests have passing tests in the same area to clear them.
(2) North Plant Dike MD 290 and HD 377 have been identified on Becht 005)
North Plant Dike HD 360 and Struen"1 Backfill NDR 621 density problems have been identified on BechtehR 10D North Plant Dike MD 360 moisture problem has been identified on revised NCR 1005.
Part 2 (1) Bechtel QC has determined that none of the above failing tests have passing tests in the same area to clear them.
(2) North Plant Dtko MD 142 and MD 143 West Plant Dike MD 227 an t Area Fill HD 1326, 1323 and 1412 have been identified on Becht.
R 1003 Struc-tural Backfill MDR 621, 671, 672, 685, and 686 have been i am i isu on Bechtel NCR 1004.
Plant Area Fill hD 1311 has been identified on revised {ER 1004]
(3) Corrective aceton has Been taken as of the last of July 1977 by Bechtel QC f
and U.S. Testing to more adequately clear failing* tests. *Therefore, the correctivo action to preclude repetition for not clearing failing tests need not be addressed.
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'5:is Cetry For File 16.3.4 & 16.3.6
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Nonconforsance ueOSegn RW No OF-203 this Nonconfor$$c#8UeNrt is Issued 2:
Prepared By N J ) C k % Date 11-11 ~7 9 e
App' roved By,kM4#5 Date M M c C. L. Richardson Bechtel Lead QAE Written Reply RequestedM Date 12/167 Corrective Action Requested By Date 12/30/~
who is resconsible for corrective action.*
Nonconformance Description and Supporting Details:
See attachment.
AEC Reportable Yes I;o See Procedure 9 (For Nuclear Projects only)
StopW$rkNecessary Yes No y See Procedure 16 - Stop Work No Ho Hold Tags Applied Recocnended Correct 1re Action:
See attachment.
Corrective Action Taken:
See attachment.
kerification of Corrective Action Required Yes @ No bethod of Verification:
Reviewed Iceters CLR-12-77-517, GLR-1-78-001 and CLR-01-78-040 from G. L. Richt.rdso to J. f.. Corley; ictters 216FQA77 and 6FQA78 from J. L. Coricy to C. L. Richardsont Actters 0-1621 and 0-1651 from J. Newgen to C. Richardson; Bechtel QC Training Session QCFM-4250; and NCR's 1055 and 1094.
bonconfonnance Closure Confirmed By ad.M b* h w l
Date -*
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t i
m be cong1sted at timo of closure by Consu:ners Power QA Services.
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Tile ~ Titlef2!CR's on Bechtel Construction cnd Quality Control i
Attachment to NCR_No QF-203 Nonconformance Description and Supporting Details:
.a Project Quality Control Instruction R-1.00, "Naterial Receiving Instruction" Section 5.2 of Revision 3 and Section 5.1 of Revision 5 states in part, " Require-ments for the sampling and testing and the acceptance criteria reference documents shall be noted on the applicable IR" and Section 5.4 of Revision 3 and 5.3 of Revi-sio.p 5 states, " Review any required user's test data reports to verify that they have been satisfactorily cospleted".
P_ art A QCIR No. R-1.00-1560 for Zone 4A Fine Backfill references User's Test Report No.
i 0630 and the acceptance criteria as:
1 Sieve Size
% Passing 1
1" 100 3/4"90-100 1/2" 75-90 i
3/8" 60-85
- 200 7-15 s
Contrary to the above, User's Test Report No. 0630 references 100% passing as the acceptance criteria for the 1/2" sieve, consequently 94% passed the 1/2" sieve
)
and it was accepted when actually it failed.
i Part B QCIR No. R-1.00-2105 for Zone 4A Fine Backfill references User's Test Report No.
}
1036 and the acceptance criteria as t
.,,Slove Sixo
% Passint 1"
100 3/4"90-100 1/2" 75-90 3/8" 60-85 i
- 200 7-15 Contrary to the above, User's Test Report No.,1C36 indicated 81% passing the 1/2" r
steve and acceptr.d, this should have indicated 91% passing the 1/2" sieve and failed.
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,u Project Midland 1 & 2 File Title NCR's on Bechtel Construction and Quality Control Attachment to NCR No QT-203 j.:
A Nonconformance Description and Suppof ting Details:
(Contd)
Part C QCIR No. R-1.00-1836 for Zone 4A Fine Baa'cfill rdferences User's Test Report No.
0336 and the acceptance criteria as:
Sieve Size
% Passing 1"
100 3/4"90-100 1/2" 75-90 3/8" 60 85
- 200 2-20 Contrary to the above, User's Test Report No. 0836 had 11% passing the #200 sieve and it was accepted.
~
Recommended Corrective Action:
P.z r t A & B 1.
Present these fi, dings to Bechtel Project Engineering so Project Engineering can determine wh;; additional tests, reviews, etc. are needed to justify the material these tests represent. Have Project Engineering determine the accept-ability of the material these failing tests represent.
2.
Determine the underlying cause(s) for these discrepancies and take corrective action to preclude repetition in other areas.
Parc C 1.
An evaluation of this material is not needed because the acceptance criteria as given on QCIR No. R-1.00-1836 was 12-20% passing the No. 200 sieve. It should have beu. 7-20%, therefore, the test result of 11% is passing.
2.
Determine the underlying cause(s) for QC not rejecting the Zone 4A Fine Back-i fill per the QCIR No. R-1.00-1836 acceptance criteria of 12-20% passing the i
No. 200 sieve. Revtew the interface between the material receiving QCE's and l
the test lab QCE's to determine if there is s breakdown in consnunicating the j
inspection criterin for materials being recuived. Take corrective action to preclude repetition.
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NCRjs on Bechtel Mid1a'nd 1 & 2
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Constructi5n~a'ukQuality Control
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Attachment to NCR No QF-203 2~
A
- CorrectiveActionTIken:
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Part A & B 1.
NCR-1094 was w'ritten to identify the, nonconforming material in Part A.
Project Engineering dispositioned this material "Use-As-Is".
NCR-1055 was written to identify the nonconforming material in Part B.
Field Engineering has disposi-
- tiened this' material " Reject For Q-Use".
This material was only used in Non-Q Areas.
- 2.,,Tha.-undetyinJ_cause of eba-- m.diti:.- >== improper review of the test ren e =
by Quality Control. To prevent this condition from recurring, a training session was held with cognizant individuals in attendance.
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Part. C 1.
Based on response given in Part A of letter 0-1621 from J. Newgen to C. Richardsor it was necessary for Field Engineering to justify the more stringent requirements and the use of this material when it did not meet these requirements. The
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justification was given by Field Engineering.
3 2.
The underlying cause of this condi::f on was that the Civil QC Engineer identified the different gradation requirements on the OCIR and failed to bring it to the attention of the QC Receiving Engineer. To preclude repetition, the cognizant QC engineers in both disciplines were reminded that close interfacing is a necessity.
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Page 4 of 4
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00f13UMER3 POMR COMPANY Bechtel Power Corporation o E3I.V E'
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e Post Office Box 2167
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,, Midland Michigan 4864o
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FliLD QUALITY ASSURANCE MIDI.AND, MlCHIGAN January 31,1978 s
1 Consumers Powe'r Company P. O. Box 1963
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,. Midland, MI 48640
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Attention:
J. L. Corley U
Job 7220 Midland Project
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CPCo NCR QF-203 Final GLR-01-78-040
Dear Mr. Corley:
Ref: 1) Letter J. Corley to G. Richardson, 216FQA77, dated 12/23/77 The following is in response to the above subject nonconfomance
[.
report which identified problems on user tests for backfill material.
For the material identified in Part A of the subject finding, NCR-1094 was written. This NCR has been dispositioned by Project Engineering as Use-As-Is, and is now closed.
For the material identified in Part B of the subject finding NCR-1055 was written. This NCR is closed as previously addressed in letter GLR-01 001.
For the material identified in Part C of the subject finding the field has provided justification as to why FMRs had stricter requirements than those given by Project Engineering. In letter G-%ti, dated 1/17/78, Fleid Engineering stated in part:
0-/6Sts,w.gt The reason for specifying a 12-20% range of aggregate passing through a f200 sieve, when Specification C-210. Rev. 5 and Dwg. C-130, Rev 6 allowed a range of 7-20%, was strictly for ecmmercial reasons. The vendor said he had a supply of "12-20%
material". When this material actually turned out to be 11%, it was still acceptable for use in accordance with our specification and drawing.
This concludes our action on the subject nonconformance report. Should you desire additional information, do not hesitate to bring it to my
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4ttention.
Very truly yours, h*
G. L. Richardson LEAD QUALITY ASSURANCE ENGINEER
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J. F. ik-won
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Ecfsr.. 2s : 1) Ltr. Pichardson to ilewgen, GLR-12 77~-532, 'dats'd 12-7.3-77 (I 8340)
- 2). Ltr. Coricy to Richardson, 216FQA77, dated 12-23-77 This -
.3 is in response to referenca 1 and is nu= bared simil5.rly.
c.ber 200 sicva, when Specification C-210, Rev. 5 alicirnd ; ian ;gh casen for specifying a 12-207, range of aggreg.ata passing thecu 1.
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~ 7.03, t;as strictly for cc:marcia.1 reasons. The vendor, said i:e had c-c pply of "12-20s material". When this material actually turnd cut
.e 11%,. it was still acceptable for use in.accordance with cur
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-i fi ca tion. Tha only,"crror" was in dispositioning ?!CR QF-203 by
.. r: : sing the Fi4?., rather.than noting to "use as is".
2.
T' it. tant of cur previous response to blank signature bioch en fir's C'
171, Rrt's 1 s 2, t as to poi.it out the.fc11 erring:
.a.
Mvisiens 'to FMR's for cc. n:ercial purposes do not fr.il endar tha QA prograin.
b.
Paragraph 3.10.2 of the IJI-1, Ray. 1 limits thi r.scassity of the approval pracass of F'4?. ravisions to th:se which add.ess spcificaticn changes.
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Cc. r.cr:lal changes to F;ia's are not.governad by F7G-3.0"g.
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c i*a disagree t!1at a generic problem currently exists in tha appr.r.'al 3.
cmpleteness of HM's. The PFE and AFFE's have indicated the ircir:Mcy of signat'ure caission is naglegib1p.,on "Q" RR's. Thosa which h.tva
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lact:ad sii.;aat.ures were returned when discovered..
4.
The PFEYn*i APFE's have intensified their surveillance of "Q" l'*2.'s to assura the requirenants of FPG-8.000 are i=plemented.
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QUALITY ASSURANCE -
SUBJECY CE IT: Soil Placement l g
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JFNewgan REPORT NO F-77-17 p
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I.
AUDIT SCOPE y M
The purpostof this record review audit is to verify the documentation associated with the placement of Structural Backfill, North Plant Dike, West Plant Dike, and Plant Area Fill conforms to the specifications and 1
to expedite dike turnover.
II.
AUDITORS I**D. A. Blumenthal, CPCo QAE (IE&TV) - Team Member
- D. E. Horn, CPCo QAE Civil Supervisor - Team Leader III. PERSONNEL CONTACTFJ
- Ben Cheek, Bechtel Lead Civil Quality Control Engineer
- Keith Berk, Bechtel QCE (QC Vault)
- Pat Guiette, Bechtel QCE (QC Vault)
- Mary Kerridge, Bechtel QC Documentation Clerk
- Tom Lieb, Bechtel QCE (Civil)
- Daryl Osborn, Bechtel Assistant Lead Civil QCE
- John Speltz, U.S. Testing Lab Chief IV.
SU!DtARY OF AUDIT A.
A Pre-Audit Conference was held on August 31, 1977 in Ben Cheek's office with those in attendance as noted in Sections II and III above.
The audit scope was the only item discussed. The audit scope originally was to observe soil placement, however, due to heavy rains and no soil placement in "Q" areas, the audit scope was changed to that given in Section I.
B.
The audit was perfermed on soil reports North Plant Dike 1:D 72 (5-23-74) through HD 514 (9-21-74), W st Plant Dike MD 25 (9-12-74) through MD 307 (9-27-76), Structural Ba kfill )mR 611 (10-7-76) through MDR 1121 (8-11-77),,
Plant Area Fill MD 1122 (10-7-76) through MD 1854 (8-12-77) and gradation reports for structural backfill material received February 4,1977 through l
August 31, 1977 to assure failing tests have been cleared by passing tests; correct optimum moisture contents, maximum and minimum dry lab densities have been used; the test results were properly evaluated for acceptance; and test reports could be located in the Quality Control-Documentation Vault using the attached checklist.
C.
The findings associated with this audit are noted in Section V.
- Contacted during Audit
- Attended Pre-Audit Conference and Post-Audit Conference
- Attended Post-Audit Conference
- Contacted during Audit and attended Post-Audit Conference eb N l
BY DATE II-Y -U
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DATE:
6.tober ^,-7, 1977 j)
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PLANT: Hidland UNIT 1&2 SUBJECT OF AUDIT: Soil Placement r
Records AUDIT REPORT NO J-77-32
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SUMMARY
D D.
Future audits will be run the same, when scheduled.
A Post-Au' it Conference was held on October 11, 1977 in Ben Cheek's E.
d office with thoss in attendance as noted in Sections II and III above.
The audit findinge were p' resented to those in attendance by D. A.
Blumenthal and D. E. Horn. Bechtel QC understood and agreed with the findings and recommended corrective action.
V.
CLOSED OUT FINDINGS s
Finding 1 West Plant Dike HD-276 and 277 (sampled 9-15-76), 278 (sampled 9-16-76), and 285 (sampled 9-17-76) have NA in the optimum raisture content column.
North Plant Dike L
HD-92 (sampled 5-25-7(,). shows maximum dry. lab decsity 110.6.
It should have been 103.4.
10-93 (sampled 5-25-74) shows maximum dry lab desnity 110.6.
It should have been 100.4.
HD-109 (sampled 5-28-74) shows maximum dry lab density 103.4.
It should have been 115.1.
HD-119 (sampled 5-28-74) shows maximum dry lab density 127.2.
It shoald have been 123.0.
HD-155 (sampled 6-4-74) shows optimum moisture content 18.8.
It should have been 18.4.
HD-l95 (sampled 6-24-74) shows optimum moisture content 11.0.
It should have been 11.6.
i HD-223 (sampled 6-25-74)'shows optimum moisture content 10.3.
It should have been 11.6.
HD-224 (sampled 6-21-7,4) hows' optimum moisture content 13.5.
It should have been 13.0.
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HD-257 (sampled 7-l1-74) shows optimum moisture content 9.8.
It should have been 10.4.
This also shows maximum dry lab density 126.8. It should havn been 127.4.
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AUDIT REPORT NO F-77-32
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C1,0 SED OUT FINDINGS w --
Findina 1 North Plant Dike (Contd)
HD-269 (sampled 7-12-74) shows maximum dry lah density 116.2.
It should l
have been 116.3.
I HD-290 (sampled 7-16-74) shows maximum dry lab density 125.2. It should have been 128.3.
HD-318 (sampled 7-19-74) shows optimum moisture content 13.0.
It should have been 13.3.
HD-336 (sampled 7-20-74) shows optimum moisture content 20.5.
It should I
have been 20.0.
HD-341 (sampled 7-25-74) shows optimum moisture content 17.0.
It should have been 15.5.
HD-377 (sampled 8-6-74) shows maximum lab dry density 109. It should have been 112.9.
1 HD-476 (sampled 8-19-74) shows optimum moisture contano 17.0.
It should 4
have been 17.1.
t HD-512 (sampled 8-28-74) shows maximum lab dry density 109.4. This should a
have been 109.0.
l Structursi sackfill Area i
Hmt-919 (sampled 3-25-77) shews maximum dry lab density of 109.3.
It should have been 125.3.
It also shows minimum dry lab density as 90.3.
It should
,have been 109.3.
Plant Area Fill HD-L262 (sampled 4-8-77) gives maximum dry lab density of 117.0.
It should-have been 117.1.
HD-l300 (sampled 5-2-77) gives optimum moisture content of 11.1.
It should have been 10.4.
HD-1385 (nampled 6-2-77) gives optimum moisture content of 13.5.
It should havn been 13.4.
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.DATE:
.tober 3-7, 1977 l.
.3 PLANT: Midland UNIT 1&2 SUBJECT OF AUDIT: Soil Placement r
Records i
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AUDIT REPORT NO F-77-32 4
d V.
CLOSED OUT FO DINCS e
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Finding 1_
Plant Area Fill (Contd)
MD-1420 (sampled 6-8-77) gives optimum moisture content of 9.3.
It should i
. have been 8.6.
It also gives maximum dry lab density of 127.3.
It should have been 132.9.
HD-1521 (sampled 6-17-77) gives maximum dry lab density of 117.0.
It should have been 117.1.
Corrective Action Requested: Recalculate the test results using the proper values and determine the acceptability of the corrected test results.
Corrective Action Taken: The test results were recalculated and corrections made. The above errors did not change the acceptance of these tests even though they did change the test results.
Corrective action verified October 25-26, 1977.
For further corrective action see Section V1 "Open Findings" Finding 1.
l Finding 2 Specification C-210 Revision 5 Section 12.6.1 states in part, "The water y
content during compaction shall not be more than 2 percentage points below optimum mof ture content and shall not be more than 2 percentage points above optimum moisture content..."
SpecLfication C-210, Revision 5 Section 13.7.1 states, "All cohesive back-fill in the plant area and the berm shall be compacted to not less than 95 percent of maximum density as determined by ASTM D 1557, Method D".
Specification C-210, Revision 5 Section 13.7.2 states in part, "All cohesion-t less backfill in the plant area and the berm shall be compacted to not less than 80 percent of relative density as determined by ASTM D 2049..."
Contrary to these requirements, the following tests had failing results j
and did.not indicate being cleared by passing tests.
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AUDIT REPORT NO F-77-32 V.
C1.0 SED OUT FINDINGS
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Finding 2 (Centd)
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Plant Area Fill Test No.
Date Sampled Compaction _
}!ois tureL Actual _
_Op timum MD 1153 #
10-21-76 10-21-76 61.6% of Relative Density 1155#
1191<
11-03-76 73.5% of Relative Density 11-02-70 74.6% of Relative Density 1194' 5-09-77 75.4% of Relative Density
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5-09-77 18.0%
15.2%
1319 5-09-77 1320 11.5%
15.2%
3-09-77 11.7%
15.2%
1321/
5-09-77 12.2%
15.2%
5 '7-77 94.0% of Maximum Density 1337-
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1388#
6-02-77 12.4%
15.2%
1393s 6-03-77 9.8%
15.2%
1398-6-03-77 11.1%
13.4%
1504 /
6-03-77 1415' 11.2%
13.4%
6-07-77 1498' 10.2%
13.4%
6-15-77 6-16-77 88.2% of Maximum Density 9.9%
13.4%
1509s 14.5%
10.0%
12.9%
15.2%
North Plant Dike HD 418 8-14-74 17.2%
20.0%
Structural Backfill _
HDR 620 10-13-76 625 /
10-12-76 72 3% of Relative Density 629 10-20-76 51.5% of Relative Density 632 10-20-76 79.2% of Relative Density 10-21-76 73.5% of Relative Density 637 663 /
11-11-76 76;3% of Relative Density 11-11-76 53.0% of Relative Density 664/
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11-11-76 72.3% of Relative Density 667/
573 11-23-76 67.5% of Relative Density s
679 11-23-76 33.9% of Relative Density
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11-23-76 71.8% of Relative Density 680 /
11-24-76 60.0% of Relative Density 682/
11-24-76 70.6% of Relative Density 688 /
1-13-77 77.1% of Relativa Density 700 1-13-77 75.0% of Relative Density 701 721/
3-14-77 68.1% of Relative Density 60.0% of Relative Density p p. w.
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,DATE:
- ober 3-7, 1977
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Pl. ANT: Midland UNIT 1&2
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SUBJECT OF AUDIT: Soil Placement Records
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AUDIT REPORT NO F-77-32 7
he V.
CI.0 SED OUT FINDINGS Finding 2 Structural Backfill (Co6td)
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Moisture
' Test No.
Date Samoled Compaction Actug Optimum
=
MDR 734/
3-17-77 34.0% of Relative Density 736/
3-18-77 79.0% of Relative Density 737j 3-18-77 41.9% of Relative Density 738,
3-18-77 72.4% of Relative Density 739 3-18-77 70.6% of Relative Density 740' 3-18-77 69.3% of Relative Density 741' 3-21-77 77.8% of Relative Density 744' 3-21-77 56.2% of Relative Density 746/
3-21-77 54.9% of Relative Density 757' 3-23-77 68.7% of Relative Density 767*
3-29-77 54.3% of Relative Density 768' 3-30-77 66.9% of Relative Density 770-'
3-30-77 65.0% of Relative Density 785' 4-07-77 69.3% of Reistive Density 799' 4-12-77 78.8% of Relative Density 82P 4-19-77 70.4% of Relative Density 8',3 -
4-28-77 66.8% of Relative Density 845 /
4-29-77 70.4% of Relative Density 854 5-09-77 67.4% of Relative Density 861 5-10-77 76.3% of Relative Density 862 5-10-77 74.0% of Relative Density 889' 5-13-77 56.5% of Relative Density 9 14 /
5-24-77 9.0%
11.8%
922'#
5-26-77 75.7% of Relative Density 925 5-27-77 11.4%
15.2%
938' 6-08-77 56.5% of Relative Density 940/
6-08-77 78,6% of Relative Density 993 #
6-25-77 60.2% of Relative Density 998 6-25-77 77.4% of Relative Density Corrective Action Requested: Determine if there are passing tests in the same area te clear these failing tests.
i Corrective Action Taken: Test reports Plant Ares Fill MD 1317-1320; North Plant DLke HD 418; and* Structural Backfill MDR 620, 629, 632, 637, 673, 679, 100, 701, 757, 761, 768 and 770 have been cleared by passing tests and Struc-tural Backfill represented by MDR 854, 861 and 862 was removed.
CorrectLve Action Verified October 26, 1977.
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- N AUDIT REPORT NO F-77-32 a
V.
CLOSED OUT FINDINGS
. s. s Finding 2 (Contd)
Corrective Ac~ tion Taken: Test reports Plant Area Fill MD 1153, 1155, 1191, 1194, 1321, 1337, 1388, 1393, 1398, 1404, 1415, 1498, 1509 and Structural Backfill MDR 625, 663, 664, 667, 680, 682, 688, 721, 734, 736-741, 744, 746, 757, 768, 770, 785, 799, 826, 843, 845, 889, 914, 922, 925, 938, 940, 993 and 998 are in a "Non-0" area and have been efven to CPCo Proicct Manage-ment Organization (Field) for resolutien.in letter 186FnA77 For further corrective action see Section VI "Open Findings" Finding 2.
f
/ Finding 3
~ Relative Density Reports 59 and 61 were missing from the QC Vaul't.
Corrective Action Requested: Obtain copies of these reports and place them in the QC Vault.
J4
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Corrective Action Taken: Copies have been obtained and placed in the QC Document Vault.
Corrective action, verified October 26, 1977.
VI.
OPEN FINDINGS Finding i Specification C-210, Revision 5 Section 12.6.1 states in part "The water content during compaction shall not be more than 2 percentage points below optimum motsture cnittent and shall not be more. than 2 percentage points above moisture content..."
' Specification C-210, Revision 5 Section 13.7.1 states, "All cohesive back-fill in the plant area and the berm shall be compacted to not less than 95 percent of inaximum density as deterained by ASTM D 1557,.Hethod D".
Specification C-210, Revision 5 Section 13.7.2 states in part, "All cohesion-less backfill in the plant area and the berm shall be compacted to not 1 css than 80 percent of relative density as determined by ASTM D 2049..."
Contrary to these requirements, the following tests had been passed using incorrect testing data. Using the correct testing data, the tests fail.
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DATE:
iober 3-7, 1977 hl
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V' n %.
' - PLWT: hadland UNIT 1&2
.,,,u SUBJECT OF AUDIT: Soil Placement r
Records AUDIT R' PORT NO F-77-32 E
VI.
OPEE FINDINGS.?c' 6%
j-Finding 1 (Contd)
North Plant Dike 10 290 (sampled 7 16-74) shows optimum moisture content 11.6.
It should be 9.5.
Using the correct optimum moisture content of 9.5%, the actual moisture content is 2.2% above optimum moisture content.
HD 360 (sampled 7-31-74) shows optimum moisture content as 21.4 It should be 15.2.
This also shows maximum lab dry der.sity as 103.2.
It should be 115.1.
Using the correct optimum moisture content of 15.2%, the actual moisture content is 5.4% above optimum moisture content. Also using the correct maximum Lsb dry density. of 115.1, the co'rrect percent of m'ximum density is 86.4%.
HD 377 (sampled 8-6-74) shows optimum moisture content as 18.0.
It should be 15.2.
Using the correct optimum moisture content of 15.2%, the actual moisture content is 4.5% above optimum moisture content.
Structural Backfill
~'
HDR 621 (sampled 10-14-76) shows minimum dry lab density as 94.2.
It should be 112.2. Using the correct minimum dry lab density of 112.2, the correct percent of relative density is 41.5.
j i
Corrective Action Requested:
(1) Determine if there are passing tests in the same area to clear these failing tests.
j J
(2) If these failing tests cannot be cleared by passing tests in the same -
aren, present these findings to Bechtel Project Engineering so P oject Engineering can determine what additional tests, reviews, etc. are needed to justify the material these tests represent. Have Project Engineering justify the material these failing tests represent.
(3) Determine the underlying cause(s) and take corrective action to preclude repetition.
l Correct 1,ve Action Taken:
t (1) North Plant Dike no 290 and HD 377 have been identified on Bechtel NCR 1005. North Plant Dike ID 360 and Structural Backfill POR 621 density prob Lems have been identified on Bechtel NCK 1004.
Corrective action verified October 26, 1977.
North Pinnt Dike HD 360 moisture problem has been identified on revised NCR 1005.
4 Cortective action verified October 28,' 1977.
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- Records AUDIT REPORT NO F-77-32 OPENFINDINGS['
d VI.
.a Finding 1 (Contd)
NCR QF-199 has been written to resolve the corrective action still open.
Finding 2 Specification C-210, Revision 5 Section 12.6.1 states in part, "The water content during compaction shall not be more than 2 percentage points below optimum moisture content and shall not be more than 2 percentage points above optimum moisture content..."
Specification C-210, Revision 5 Section 13.7.1 states, "All cohesive backfill in the plant area and the berm shall be compacted to not less than 95 percent of maximum density as determined by ASTM D 1557, Method D".
Spe.cification.:-210, Revision 5 Section 13.7.2 states in part, "All cohesion-less backfill in the plant area and the berm shall be compacted to not less than 80 percent of relative density as determined by ASTM D 2049".
Contrary to these requirements, the following tests had failing results and did not indicate being cleared by passing tests or had been marked passing.
North Plant Dike HD 142 (sampled 5-30-74) shows optimum moisture content 8.0, moisture content 10.3.
This tert failed but it is shown as passing.
MD 143 (sampled 5-30-74) shows optimum moisture. content 13.8, moisture content 11.4.
This failed but it is shown as passing.
West Plant Dike HD 227 (sampled 10-6-75) failed moisture but has not been cleared.
Plant Area Fill Moisture Test No.
Date Samoled Comosction Actual
_ Optimum HD 13L1 5-03-77 61.6% of Relative Density 1326 5-10-77 18.5%
15.2%
1328 5-10-77' 12.2%
15.2%
1412 6-07-77 10.4%
15.2%
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.. PIANT:
.idland UNIT 1&2 4.
SUBJECT OF AUDIT: Soil Placement Records
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AUDIT REPORT NO F-77-32 VI.
OPEN FINDINGSJ-M
.f.
Finding 2 (Contd)
Structural Backfill Moisture Test No.
Date Samoled Compaction Actual Optimum MDR 621 10-14-76 78.0% of Relative Density 671 11-12-76 74.8% of Relative Density 672 11-23-76 75.4% of Relative Density 685 11-24-76 56.2% of Relative Density 686 11-24-76 70.9% of Relative Density 691 11-24-76 62.0%.of Relative Density Corrective Action Requested:
(1) Determine if there are passing tests in the same area to clear these failing tests.
(2) If these failing tests cannot be cleared by passing ' tests in the same area, present these findings to Bechtel Project Engineering so Project Engineering can determine what additional tests, reviews, etc. are needed to justify the material these tests represent. Have Project Engineering justify the material these failing tests represent.
(3) Determine the underlying cause(s) and take corrective action to pre-clude repetition.
Corrective Action Taken:
(1) Rechtel QC has determined that none of the above have passing tests in the same aren to clear the failing. tests.
I (2). North Plant Dike MD 142 and MD 143, West Plant Dike MD 227 and Plant Area Fill MD 1326,1328 and 1412 have been identified on Bechtel NCR 1005. Structurni Backfill MDR 621, 671, 672, 685, and 686 have been identified on Bechtel NCR 1004.
(3) Corrective action has been taken as of the last of July,1977 by Bechtel i
QC and U.S. Testing to more adequately clear failing tests. Therefore, the corrective action to ;reclude repetition for not clearing failing tests need not be addressed.
Corrective action verified October 26, 1977 Pinnt Aren Fill MD 1311 has been identified on revised NCR 1004.
i Corrective action verified November 1, 1977.
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NCR QF-199 has been written to resolve the corrective action still open.
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AUDIT REPORT NO F-77-32 1
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OPEN FINDINGSJ- (Contd)
Finding 3 **
- Specification C-211 Revision 3 Section 5.6.2 states in part " Material de-livered to the jobsite for use as structural backfill shall be visually in-spected, and tested in accordance with ASTM C-136..."
ASTM C136-71 Section 4.'2 states in part, "In no case, however, shall the frac-tion retained on any sieve at the completion of the sieving operation weigh more than 4g/in.2 of sieving surface.
Note 2 - This amounts to 200g for the usual 8 in. (203-mm) diameter sieve".
To preclude repetition to NCR QF-152 (the same deficiency as this), U.S.
Testing developed a new gradation form that has check points that include documenting that the 200 gram material limit on any individual 8 inch sieve has not beert exceeded.
In addition, a training session was held on February 21, 1977.
Y Project Quality Control Insert.ction No. SC-1.05 " Material Testing Services and Concrete Production" Rev. 3 Section 2.7.2 Reports, Item A states, " Perform a daily review of the subcontractor's jobsite inspection and test reports for acceptability, completeness, and the laboratory chief's signature for concrete, steel, and soils. Sign and date on the report verifying the acceptable status".
Contrary to these requirements:
Structural Backfill Date Sampled Amount Retained Log Number G-270 1-13-77
- 40 Steve - 225.2g 0364 4-27 #10 Sieve - 217.lg 4
0417 5-11-77
- 10 Sieve - 221.4g 0431 5-16-77 910 Sieve - 260.lg i
0451 5-18-77
- 10 Sieve - 211.7g 0505 6-02-77
- 200 Sieve - 228.0g 0704 7-18-77
- 10 Sieve - 249.5g Corrective Action Requested:
(1) Present these findings to Bechtel Project Engineering and obtain engineer-ing rationalc from Bechtel Project Engineering as to the acceptability i
of the matertal these tests represent.
(2) Evidently the corrective action taken in NCR QF-152 was not adequate.
Determine the underlying cause(s) and take further corrective action to precludo repetition.
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AUDIT REPORT NO F-77-32
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wt VI.
OPEN FINDINGS ~-
Finding 3 "(Contd)
Corrective Action Taken:
(1) These findings have been identified on Bechtel NCR 1006.
Corrective action veri-fied October 26, 1977.
NCR QF-195 has been written to resolve the corrective action still open.
VII. NONCONFORMANCE REPORTS QF-195 QF-199 4
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9 and Inspection OA sUBJ FILE
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AUDIT SCOPE.",
y The purpose 'bf' this audit is to' verify that sofis placemr.
and in:,pection are being accomplished in accordance with Bechtel's proced2.es, specifications and codes.
II. AUDITOR G. B. Johnson, CPCo Field Quality Assurance Engineer (Civil)
III. PERSONNEL CONTACTED
- Ben Cheek, Bechtel Lead Civil Quality Control Engineer
- Daryle Osborn, Bechtel Quality Control Engineer (Civil)
IV. SUMK3RY OF AUDIT A.
A Pre-Audit Conference was held on May 23, 1977 at Daryle Osborn's desk with those in attendance as noted in Sections II and III above. The audit scope was the only item-discussed.
~
B.
The audit was performed on the placement and inspection of zone 2 material P
in the plant area South of the Turbine Building at elevations 620' - 622'.
The backfilling operation was centered around plant coordinates S 5070 and E 36Q., The attached checklist was used.
C.
The soils placement and inspection seemed adequatd except as described in Section V of this report.
D.
Future audits will be run the same, when scheduled.
- E.
A Post-Audit Conference was held on June 16, 1977 in Ben Cheek's office.
with those in attendance as noted in Sections II and III above. The Post-
. Audit Conferenco consisted of telling Ben Cheek and Daryle Osborn that the 1
results of this audit were adequate except for Findings #1 & #2 in Section 6 CLOSED OUT V.
- FINDINGS, Finding #1 Bechtel Specification 7220-C-210. Rev. 4 Section 12.6.1, states in part:
l g The water enntent during compaction shall not be more than 2 percentage points below optimum moi tnre co.itent and shall not be more than 2 t
'/,
percentage points aboca opti.:im moisture content.....
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- Attended Pro-Audit Conference and Post-Audit Conference
- Attended Post Audit Conference
. Nd. /bM DATE $ tov T7 SHEET 1
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Report No F-77-21 l
CLOSED OUT
$b V.
FINDINGS
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Findinq#1(Contd)
Contrary to These Requir ements:
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w Backfill was placeci at.a lift which Was determined to be greater than
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2% below optimum mc'is ure content (Plant Backfill Test #1352, optimum 15.2%, actual 12.8",). When questioned, the Foreman directirg the : soils 2~
work stated that he vculd continue backfilling since satisfactory
.a-compaction had beem attained.
0:
Recommended Corrective Acf.on:
l.
Th dir ecting the soils work should be instructed as to the required moistu.re content limits.
2.
Bechtel QC should determine if a re-test had been accomplished on the lift in que:stin. If a re-test had not been. accomplished.it v,
will be necessa.ry to obtain one.
If the affected material is found.
to be nonconforvirg, gn evaluation will have to be made tas to the acceptability o-f te in-place material by Pro,je,ct Engineering.
i Corrective Action Taken:
1.
Dechtel QC infct wl th forema directing the soils work of the required moistui e :onten
. ts and what to do if a failing test occurs.
~
2.
A retest was tamer in the area and the retest passed (Plant Backfill Test 1414).
- FindinM2, Bechtel Specificattor. C-20L Rev.10, Table 9-1,. states in part:
Field Densities and "'.risture Contents will be taken at the frequency of one test per every 5DI cubic yards of fill.
Contrary to These Requir:rnents:
During the audit it wu discovered that the Foreman directing the soils work believed that :nt required frequency for testing of field density and moisture conten:. ws one test per 1000 cubic yards of fill.
Reconnended Corrective Acgn:
Tkenun dir:
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the soils work should be instructed as to the correct cesc o e.gency requirements.
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FINDINGS Find'ing #2 (C.d.'ntd) wt
'l Rcccar.iended$orrective Action: (Contd)
M.i 2.
Bechtel QC should determine if the 1/500 cy test frequency has been exceeded. If the test frequency has been exceeded, an evaluation will have to be made as to the acceptability of the in-place material by Project Engineering.
Corrective Action Taken:
Y 1.
Bechtel QC informed t forema directing the soils work of the correct test frequency r rements.
2.
Bachtel QC made an evaluation concerning the frequency of testing in the affected area. It was determined that between 5/13/77 and 6/17/77, 18,200 cy of random backfill was placed South and East of the Turbine Building. 57 tests were taken on this material which results in an overall test frequency of 320 cy/ test. The majority of this 18,200 cy was placed in a NON-Q area.
VI. MONCONFORMANCE REPORTS
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U. S. Testing Company, Inc.
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Hoboken, New Jersey 07030
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Attention: Mr. D. Edley
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Job 7220 Midland Project Subcontract 7220-C-208 oos Failure of Fill Supporting ineg %,. ',
Administration 3uilding caC -
M 3eam at Column Line 0.4 C-208-B-286
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Reference:
Telex Number C-208-B-233 Dated December 30, 1977 From J. F. N
Dear Mr. Edley:
---~~:---
1.
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Pursuant to the referenced Telex,- we have conducted an evaluation of the suy.tetit'.".f, failure condition.
Our engineering analysis has determined that the failur caused by insufficient compaction of the fill which was placed in May and Jb'ne- ~~~ vien -
4 of 1977. A careful. review of the test data.provided by U. S. Testing Conpa ' ** ~~
dicates that this fill was erroneously reported to be '.n conformance with De.hte' Specification requirements by U. S. Testing Company.
. ais conclusion is sup oJted-- -- -*
by t!e following facts.
TQ]
L 1.
A sur=ary of fifteen (15)' compacted fill density tests takec. by U. S.- Testing to evaluste the subject fill as it was co=pacted is provided in Tabla fl. The location of each test is plotted in Figurc fl..Although several initial tests indicate test failure due to insufficient co:r.paction, each failure is properly cleared by a passing test at or near tha location of the failure.
2.- luximum laborataqr dry density value (from Ecchtel Modified Proctor Tests) used as the standards for evalusting acceptability of fill compaction varc -
selected by U. S. Testing Lab Technicians.- In a Jobsite necting uith F.
Teague and B. Check of Bechtel, J. Spcitz of U. S. Testing stated that the testing 'tochnician uses a visual comnarison between soil characteristics (primarily color) of the in-place saepla and bottled sampics of material uith known maximum laboratory dry density, to select the appropriato ston-=
6 dard. Visusi examination by Bechtel soils engineers of the subject fill i
during the subsequent grade bean renoval indicated the material van uniforrs in appearance with minic:sl variation in soil characteri.= tics (color and Plasticity) over the full crtent of the fill.placc=ent.
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- 3. ' The value of naxicun laboratory dry density selected for comparison of the in-place dry densities in the subject fill varien between 132.9 lb./f t.3 and 116.0 lb./ft.3 This variation includes norit of the full ran3e of mani=um inboratory density standards uhich represent significantly differing soil characteristics of the clay soils in use on this project. A graph of the caximun laboratory dry density plotted with the corresponding in-place dry density for cach test is given in Figure #2. Note that for three compacted fill density tests (1469,1494 and 1493) taken within a few feet of each other and at the same elevation, two significantly different maximum labora-tory densities were used as the compaction standard by the same U. S. Testing technician.
4.
Iesting during removal of the subject fill was conducted by U. S. Testing in accordance with Bechtel direction and Specification 7220-C-200 requirements.
A summary of test data and results is given in Table #2. The results of com-pacted fill density tests taken during subject fill re= oval confim dry den-sity values taken during initial fill. Bechtel modified proctor tests taken during fill removal in three locations (one at the north and south edges of the fill and one approxisately in the center) confirm that the maximum labo-ratory dry density was uniform as the appearance of the material indicated.
In addition, the subsequent testing indicates the value of maximum laboratory dry density uns betueen 130.5 lb./ft.3 and 133.1 lb./ft.3 From these test results it is apparent that' the lower na cinun laboratory dry density standards selected during the original fill testing were not appropriate. As shown in Table #2, this error resulted in actual compaction in the*-rinige of 33.17. to 90.5% of optinurt for three areas of the subject fill, a substantial deviation
~
from the 95:: of optimum co=paction required by Specification 7220-C-203.
In conclusion, the U. S. Testing $ Company failure to report deviations from specified conpaction requirenants which was the result 'of repeated erroneous salcetion of co:-
paction standards by U. S. Testing Company. c: ployee represents a violation of the j
Specification 7220-C-203,Section II, requirement and U. S. Testing Company is therefore liab~ c for cos associated with the su sequent failure of the fill. Such costs incit.Ic but are no limited to the cost of removal and investigation of the original beam and its cu porting fill in addition to all replacanent costs which acounts to a total of $ 4,600.00. An outline 'ite=izing these costs is provided as Attachment #2 of thi letter.
Ue trust U. S. Testing ompany, Inc. will fulfill its contractual obligations with respect to this matter in a titely manner.
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Very truly yours, r
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/'J R. Heroeston P. A. Martinez d
J. Spnitz f
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AVERACE COUNT AREA:
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DATE OF TEST 91@/22./77 W22/n
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'7, DENSITY RIQUIRED 9 7/,
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MOI STURi-: TOI.ERANCE R!MUIRED 2 f.
T. 2,P, r 793 l. '! Z $
94/.67 9R. 2.
% Fl E!.D DENSITY 92.7 4'4-7 Pu PASS F=FA I LUR 5'
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Administration Building,. Original.. Fill-N '<.
(Tests Crouped by Ceneral Area and Date of Test)
-~ TEST DATE TESTED IN-PLACE MAX. LAU.
KO.
TAKEN EY LOCATION ELEV.
DRY DENS.
DRY DC!!S.
COMP.
.RF2fARKS
_ 911 ' 5-23-77 SM 2' N. of N. Steam 614.5 133.1 132.9 100.2 Pass Tunnel tra11 - 25'
- 11. of. Turb. #1 914 5-24-77 SM 2' N. of Steam 614.6 125.7 123.9 101.5 Fail - Moistur-Tunnel ifall - 50' (Too Dry - 97.)
- 11. of Turb. fl
. 1403 6-3-77 RS 4' N. of N. Itall 621.5 111.0 116.0 95.7 Pass Ste:!m Tunnel - IS' U. of 1.0 1404 6-3-77 RS 5' N. of N. Wall 623.0 115.7 121.0 95.6 Fail - Moisture Steam" Tunnel - 24 '
(Too Dry - 10.~
- 11. o f 1. 0
..1362 5-27-77 SM 10' N. of Steam 615.5 114.2 117.0 97.6 Pass Tunnel - 4' E. of C. Side
.1422 6-8-77 BS 8' E. of E. Steam 622.0 117.7 123.9 95.0 Pass BT Tunnel - 24' N. of N. Stean Tunnel 1469 6-13-77 LG G' S. Hk line',',,4 '
617,.0 115.2' 127.3 90.5 Fail. - Comp.
E. of E. Steam Tunnel Hall
~1494 6-15-77 RS 8' S. of Hic IInc 617.0 110.2 117s0 101.0 Pass - Rctest 4' E. of E..Secan Clears 1469, 14 Tunnel !!all
~
1493 6-15-77 RS -
8 ' S. o f Ut; line.
617.0 112.2 127.3 38.2 Fail - Comp.
S' E. of E. Steam
!!all
~
1491 6-15-77 BT S' E. of E. Steam 618.0 113.0 127.3 GB.3 Fail - Comp.
Tunnel Wall - 46' N. of N. Stcan Tunnel Unli
.1517 6-16-77 DT 5' E. of E. Steam 620.0 119.7 123.9 96.6 Pass Tunnel Wall - 60' N. of U. Unli
.1519 6-16-77 BT 8 ' E. o f E. S team 618.0 124.0 127.3 97.4~ ~ Pass - Retcsc
~
Tunnci Wall - 48' Clears 1491 N. of N. Wall 1492 6-15-i/
BT 33' W. of 1.0 - 5' 626.0 116.2 127.3 91.3 Fail - Comp.
N. of N. Steam Tunnel Hall j.1518 6-16-77 LT 30' W. of -1.0 - 5 '. 626. 0 122.7 127.3 96.4 Fail - Moisture
~
M. of M. Unl1 1520 6-l'6-77 BT
~I6' T of 1 0 - S' 626.0 122.7 127.3 96.4 Pass - Roter.t N. of N. Wall C1 carn 1492, 15 r
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.*;..;'..g..ge., W-J -e TAP,LE b.~'2'~
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Q. t. nary of Test-Data a.d Rcsult. -4 bu.
r for C'D' ~
Till Below Original 2eam at 0.4 Line Adninistration Building (All Tests by U. S. Testin.N ELEVATION TEST RESULTS TEShPJSULTS TEST RESULTS NO' DESCRIPTION OF TEST OF TEST AT COLUICI HT
~AT COLU-El LN AT COLU?ci FA C0:
Initial Conpacted-617' In " lace Dry In-Place Dry In-Place Dry i
Fill Density Test Den.s'ty 4
Density w
Density
=
=
118 lb./ft.3
/119.7 lb./ft.3 114.2 lb./ft.3
/ Test No..494 Test No. 1517 Test No. 1362
/
Proctor Selected by 61'l' U.S.T. Technician EMP - 278 BMP - 262 E!P - 278 Ibx. Lab. Dry Max. Lab. Dry
! fax. Lab. Dry for Item No. 1 Tests Density =
Density Density
=
~
=
117 lb./fc.3 123.9 lb./fc.3 117 lb./f t.3
?
In-Place Proctor 617' i E!T - 300 EMP - 299 B!P - 293 After Bean Re= oval Max. Lab. Dry
!!ax. Lab. Dry Itax. Lab. Dry Density Density
=
Density
=
=
132.2 lb./ft.3 133.1 lb./ft.3 130.5 lb./ft.3 Reported %
617'.I,,
101%
Compaccion 96%
97.6%
B T Conpaccion Usin;:
617' 89.3%
89.9%
37.5%
C-In-Place Proctor anpacted Fill Den-617'
- Dry Density Ifp & 0.4 Dry Dry Density
=
sity Tested Af ter 119.7 lb./ft.3 Density D -
=
kan Renoval 108.5 lb./ft.3
=
-117.5 lb./ft.3
' Cocpaction Usin:
617' 90.5%
88.3%
83.1%
.a-Place Proctor &
' y Density Taken
'. ect Pcan Renoval anc of Three Tests at This Location ode:
L.
Test Resylts do not include failin:; tests which scre cleared by rctest I.
Reported % Compaction during initial fill compaction l
Actual % Compaction eniculated using Iten No.1 tests divided by' Item No. 3 proctor infornation TL~
I Tests taken af ter footing removal were not numbered by U.S.T., and were submitted for information only to Bechtcl. Copies of reports arc included as Attach =ent To. 1 e