ML20091L021

From kanterella
Jump to navigation Jump to search
Summarizes 800116 Meeting W/Util Re Plant Fill Settlement Issue & Licensee 791119 Response to Supplemental 10CFR50.54(f) Questions 24 Through 35
ML20091L021
Person / Time
Site: Midland
Issue date: 01/21/1980
From: Gallagher E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Fiorelli G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17198A223 List: ... further results
References
CON-BOX-01, CON-BOX-1, FOIA-84-96 NUDOCS 8406070295
Download: ML20091L021 (2)


Text

{{#Wiki_filter:,. _ _. _ [ g,8.,. ~- w-i L, (HCCM / pgLH4-A. UNITED STATES j NUCLEAR REGULATORY COMMISSION t I REGION !!I 799 ROOSEVELT ROAD .i GLEN ELLYN. ILLINOls 60137 I January 21, 1980 i G. Fiorelli, Chief, Reactor Construction and Engineering Support Branch D. h. Hayes, Chief, Engineering Support Section 1 I. J. Gallagher i 1EETING WITH CONSUMERS POWER COMPANY 'EGARDING MIDLAND UNITS 1 AND 2 PLANT FILL , 1980 s held on January 16,1980 regarding the Midland plant fill settlement issuewith Co

  • ,f) questions 24 through 35 issues on Nove 1

Th'e ' the presentation materials distributed during th 19, 1979. e meeting. i observations were made during the meeting: nificant safetyissues regarding the su situation since October 1978.

e transfer of lead respons$bility from IE to NRR was ma lovember 17,1978, no progress has been made in the nical review of the outstanding plant fill safety issue.

e the Corps of Engineers has been contacted by NRR to tw the issues, in October 1979, no progress has b regarding a technical review. een ! the NRC order of Decerber 6,1979 to Consumers P iny was issued, work has been permitted to continue ower o the wording of the order. j sted by the Licensee the order would not be effect T j a date specified following a hearing. + The Licensee equested a hearing; therefore, the order is inef fective ark continues in the light of significan tures and cooponents. ae 8406070295 840517 PDR FOIA RICE 84-96 .PDR

a y' e./. '!/ G. Fiorelli .O .,.~ 2 1/E1/80 f. 5. Consumers Power Company and Bechtet are 9roceeding with / construction of remedial measures on the foundation

  1. /

the plant without any review by.the NRC !}taff and without I* of the proposed actions.any committal by NRR as to the fe f J 1 ~ In view of the above, I believe that measure y 1 o preclude t a technical review of the suitability is complete. l n => "0' E. J. Gallagher Reactor Inspector

Enclosure:

As Stated i ec w/o encl: i J. G. Keppler e' D. W. Hayes t R. C. Knop g T. E. Vandel

j R. B. Landsman t/

e. 4 Ii .I 1 Lv-I 128 } y g g... e .) .4e ', ). i. g.,. g'. :, . 4 4 ". 'd $. .e _~ _... _. _ _.

~ %PWu, g 4 j, (O is h 0 hit:5) i } f"" "*% umTeo starts NUCLEAR REGULATORY COMMisslON J. - j%.. W ) j WAsWNGTON. D. C. M56 i s JAN 121979 % *'.v / + DOCKET NOS. 50-329 50-330 APPLICANT: Consumers Power Company FACILITY: Midland Plant, Units 1 & 2

SUMMARY

OF DECEMBER 4,1978 MEETING ON. STRUCTURAL

SUBJECT:

SETTLEMENTS On December 4,1978, the NRC staff met in Midland, Michigan with Consumers Power Company (CPCO), Bechtel Associates, and consultants in geotechnical engineering to discuss excessive settlement of the Diesel Generator (DG) Building and pedestals, and settlement of other, These technical discussions followed seismic Category I structures. a site tour on December 3,1978 during which the NRC staff observed each of these structures. Attendees for the tour and technical dis-cussions are listed in Enclosure 1. is the agenda used during the technical discussion. p

===1. Background=== 9 Pursuant to 10 CFR 50.55(e), CPC0 notified Region III of the Office of Inspection and Enforcement (I&E) on September 7,1978, / that settlement of the Midland DG Building foundation and generator pedestals was greater than expected and that a sofis boring program had been started to determine the cause and extent of the problem. An interin status report was provided I&E by CPCO's letter of September 29, 1978. I&E conducted inspections on this matter on October 24-27,1978 and issued inspection report number 50-329/78-12; 50-330/78-12. ,2. History The Bechtel representative identified the Category I structures and the type of material supporting the structure: a. Containment - Glacial Till y b. Borate,d Water Storage Tank - Plant Fill k c. Diesel Generator Building and Pedestal - Plant Fill 4 d. Auxiliary Building - Part Glacial Till & Part Plant Fill 4 ] .er - Service Water Intake - Glacial Till (Completed portion only) '~ e. - Plant Fill (Small portion yet to be j constructed) k,([)f 1 7 V L_ e ,a.

JAN 121979. 'The settlemant monitoring program began in June 1978; to date 'the measured settlements are as follows: T Containment - 1/4" to 5/8" over last 1-1/2 years Auxiliary Building - Approximately 1/8" (central portion) Service Water Pump House - O to 1/8" Diesel Generator Building - 3 to 4" since footing was poured October 1977 and walls in Spring 1978. The four electrical duct banks rising into the DG Building, and which extend downward into the glacial till, were cut loose to remove the settlement restriction on.the north side of the DG Building. When the duct banks were cut loose, settlement on the j order of 2" occurred on the north side of the DG Building at a rapid rate. The east wall exhibited rapid settlement (1/8" in one week), but the west wall showed vary little subsequent settle-. ment. This indicates that the east wall was being held up by the duct pedestal. 3. Soils Exploration Bechtel discussed the soil exploration program, including the / boring program and laboratory testing of the foundation materials. The conclusion that was made by Bechtel is that the material varies across the site in strength properties, i.e., unconfined compressive strength from 200 PSF to 4000 PSF and shear strength from 100 PSF to 2000 PSF. The soils classification ranged from Cl to Ml. Bechtel also discussed possible causes based on input from a con-sultant, Dr. R. Peck. Some of these causes were: (1) Variable quality of material used in the plant fill, however, the quality control records do not indicate the variation. _ (2) Fill may have been placed on the dry side of optimum moisture, and then when the water table rose inundating the fill, the material may have become " soft." =(3) Inittai' fill may have been placed satisfactorily but after I installing pipe trenches-and duct banks, the fill may have been disturbed. p l l i

3 JAN 121979 b 4. Consultants Perspective Dr. R. B. Peck stated the following: k a The compacted fill is comprised mainly of glacial till and i was excavated from the cooling pond area. b. Evidence exists from the Dutch cone curve that the looser and softer areas are limited to local zones or lenses. i c. Water content is higher than at the time the fill was placed. Settlement of the till has been occurring since original placement of fill, accelerated by increased moistuie content resulting from filling of the discharge cooling pond. Soil settlement is occurring unde' its own weight and the added l weight of the building is believed to be insignificant. d. The DG Building would probably not have settled as much if the j material had not been so wet (moisture content is high). Bearing capacity is not a problem for the footings. e. f. Short of removing all the fill above the hard glacial till, a "preload" program would be the best approach. The preload j purpose would be to consolidate the fill materials. g. The settlement with the preload would tend to be rapid (a i few weeks to a few months), / 1 i h. The preload is a necessary first step even though other measures j might be necessary. 4 1. The main unknown is what might happen to the rate of settlement as the water table rises and saturates the fill, 4 J i

j. Preloading would occur in early 1979 and the sand used as the surcharge would ba removed in mid-1979, Mr. C. J. Dunnicliff of Goldberg, Zoino, Dunnicliff & Associates described the instrumentation program to monitor the settlement af the foundation material and structures during the preload, i

i The purpose of the instrumentation is to determine if the surcharge i is doing its job of consolidation and if it is causing any ham j to_the structurps or utility lines under and around the building, .k 5 m: N, l t w + ~ p4 ,,s y ,-,..,,-u,,,ee_ ,m,,, ,e,s- < - -, +,. --w

i l D. JAN 121979 { }, Instrumentation for the structure will include optical survey E a. measurements as well as monitoring of cracks using electrical devices. Four locations for the electrical devices have been I chosen; two.on the exterior of the east wall of the DG Building and two on the west wall of bay number four in the DG Building. A mapping of cracks will be developed. i b. Foundation monitoring will inclu_de devices to measure settlement and pore water pressure. A total of 60 anchors will be installed (20 groups of 3 at different elevations). A total of 40 piezometers are to be installed to measure the pore water pressure. i i 4 The consultants indicated that 6" settlement would not be a surprise i and that up to as much as 18" could occur. The preload will be 2 made up of 15 to 20 feet of sand piled in and around the DG Building. No more than a 5-foot differential in the sand level 1 l between bays would be pemitted. i j The NRC questioned the effect o' settlement and preloading on the f condensate lines located under the DG Building. Fixed points j for the piping, such as the Turbine Building wall, are also of interest for the potential of cantilever effects. Sechtel explained that the 20-inch condensate lines are encased in 24-inch lines s surrounded by concrete and resting in well compacted sand. Instrumentation will be included to monitor the condensate lines, i The possibility of cutting the lines loose at the DG Building and i the Turbine Building is also being studied. The condensate lines j have no safety-related function for the Midland design. The NRC also expressed concern for the effect of settlement on the fuel oil lines under the building. CPC0 stated that re-routing of lines can be readily acconnodated if necessary. This matter is glso under review. The NRC Resident Inspector asked for a list o.3 the equipment, with-a discussion of the compacting capability and limitations of each, usetr'for compacting the fill for the DG Building from elevation j 618 to 628 feet. Bechtel will provide this infomation. 4 5. Program Status Beebl suma ized the activities completed, in progress, and planned for the future: i i g .m _/ I y -._ _~._._- _.,_

j JAN 121979 h 5-a. Activities Completed j . (1) Boring program (2) Isolation of the electrical duct banks on the north side of the OG Building i b. Activities in Progress (or soon to be initiated) (1) Foundation settlement monitoring program (2) Preload instrucantation program (3) Actual preload of the structure and foundation (4) Filling the cooling pond to maximum elevation (Elevation 627) 4 i (5) Complete construction of the rest of the DG Building structure l c. Activities Planned \\ a ,/ (1) After removal of the surcharge, a:;sure contact between i footings and soil foundation material 4 (2) Verify utilities and structure integrity j 6. Project Schedule Bechtel presented the following project schedule infonnation: Construction is 58% completed as of November 1978 Engineering is 80% complete Structural concrete is 97% com)lete 4 Fuel load target date is Novem>er 1980 ~' Earliest requirement for one diesel generator is January 1980 Current completion date for one diesel generator is January 1980 Latest date for one diesel generator is June 1980 f

  • ~ _,

i ., T N 4 -, - -. - + y, y .-c,. w ~ m ,y- ,c-wr--

l~ 1 JAN 121979 ^. 6-j l i Bechtel emphasized that the installed instrumentation will show 1 i when the preload surcharge may be removed and therefore the present t 4 schedule is somewhat tentative. Most settlement is predicted to occur rapidly as the area is being preloaded ar.d frequent readings will be taken during this period and used as a basis for further projections. ' The rate of settlement will decrease thereafter and the total settlement is expected to be reached within a few months. i CPC0 stated that if ne~ cessary, temporary diesels could be used i during preoperational testing prior to fuel loading and that j this matter is presently under study. 7. Response to Open Items in NRC Inspection Report Bechtel addressed the open items included in NRC inspection report i Nos. 50-329/78-12 and 50-330/78-12. CPC0 stated that a written e4 response would be sent to I&E Region III to resolve the conflict l between the FSAR and site implementing procedures: Conflict between FSAR Table 2.5-14 and Table 2.5-10 regarding a. 1 the description of fill material and what was actually used in the random fill: Bechtel stated that this conflict was an oversight and that an FSAR amendment would be issued. g l The NRC staff stated that any such amendment should address both the previous and the adjusted entries such that the / basis for the previous staff review is not obscured in the documentation. b. Conflict between FSAR Table 2.5-21 and Bechtel Specification C-210 regarding number of passes for compaction: Bechtel i stated that FSAR Table 2.5-21 is for the embankments for the cooling pond dikes. 4 c. FSAR Section 3.8.5.5 regarding expected settlement: Bechtel stated that 1/2-inch indicated in the FSAR was a mistake and j that the FSAR would be amended to correct this mistake, i d Conflict between FSAR Figure 2.5-47 and project drawing regarding foundation elevation: Bechtel stated the elevations in the FSAR was also a mistake and would be corrected. i Conflict fi$ Bechtel Specification C-210 regarding compactive effort: Bechtel stated that Field Change Request C-302 dated 10/31/75 clarified this conflict and permitted the j ". Bechtel Mod,1fied Protector" using 20,000 ft-lbs compactive 8- 'i i beffort rather than the ASTM standard of 56,000 ft-lbs. i .) i l

i - - ~ 4 i 3 JAN 121979 -b, /' "f. l 3~ Conflict between Dames & Moore recomendation regarding lift i thickness of 6 to 8 inches and the Bechtel specification permitting + up to 12 inches: Bechtel stated that the greater depth per-t j mitted by their specification should not matter because of perfomance qualification tests. However, the NRC was then informed that the test qualifications performed were for Zone 1 clay only, and that no test qualifications on the random fill 1 material using 12 inches was performed to qualify such lift thicknesses. Dr. Peck stated that the thicker the layer, the more differences in compaction through the thickness of the layer would occur. g. Tolerance of t 2% in moisture content permitted in Bechtel Specification C-210: Bechtel stated that this tolerance is in line with industry practice. Dr. Peck was asked his view on this i 2% tolerance. He ) stated that the important question is "t 2% of what material." Since the material used in the fill was variable, the i 2% tolerance could cause a problem if the material is not consistent. h. Cracks in the building structure: Bechtel stated that all cracks greater than the ACI 318-71 limit would be identified and repaired after the preload program. t'. FSAR question 362.2: Bechtel stated that the answer had been sent to NRC via FSAR revision 15 in November 1978. CPC0 stated that the reply to the inspection report is in process, and that the reply will include copies of all data, slides, and drawings presented during this meeting. In concluding remarks,.CPC0 stated its intent to proceed with the preloading program as described during the meeting. In its closing coments, the NRC staff stated that the proposed solu-tion is at the risk of the applicant and that NRC intends to review and ey31uate this matter in accordance with the original compaction requiremerts as set forth in the commitments in the PSAR. The staff-also stated that while attention to remedial action is important, determination of the exact cause is also quite important for verifying the Jdequacy of the remedial action, assessing the extent of the matter relavive to other structures, and in precluding repetition of such matters in the future. ,2:~-bJu I> c Darl Hood, PIject Manager Light Water Reactors Branch 4 / Division of Project Management

Enclosures:

As stated = the

  • O*

]- t.onsumers Power Company JAN 121979 ^ [ ces:. 7 Michael I. Miller, Esq. Isham,+ Lincoln & Beale 1 Suite 4200 One First National Plaza Chicago, Illinois 60670 Judd L. Bacon, Esq. Consumers Power Company 212 West Michigan Avenue 4 Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 j Myron M. Cherry, Esq. One IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711.Summerset Drive 4 t Midland, Michigan 48640 Frank,J. Kelley, Esq. Attorney Genera) State of Michigan Environmental Protection Division j 720 Law Building l Lansing, Michigan 48913 J Mr. Windell Marshall Route 10 r j Midland, Michigan 48640 Mr. S. H. Howell Vice President ConsuTner's' Power Company 212 West Michigan Avenue Jackson, Michigan 49201 4 4 w x. __ / 96 es e n - - - +

I ,j ENCLOSURE 1 3 JAN 121979 ATTENDEES DECEMBER 4, 1978 MEETING ) P. A. Martinez, Bechtel Karl Wiedner, Bechtel (

  • 5. S. Afifi, Bechtel R. B. Peck, Bechtel Consultant
  • W. R. Ferris, Bechtel M. O. Rothwell, Bechtel
  • D. B. Miller, CPC0 - Project
  • J. P. Betts, Bechtel W. L. Barclay, Bechtel 4
  • A. J. Boos, Bechtel G. L. Richardson, Bechtel
  • D. E. Horn, CPC0 - QA W. R. Bird, CPCO-QA
  • R. M. Wheeler, CPC0 - PMO
  • C. A. Hunt, CPC0 - Engineering Services

+ D. E. Sibbald, CPC0 Project ) John Dunnicliff, Bechtel Consultant

  • Austin Marshall, Bechtel - Geotech
  • 'Y. K. Lin, Bechtel - Geotech
  • B. C. McConnel, Gechtel - Geotech
  • B. Dhar, Bechtel
  • N. Swanberg, Bechtel
  • Darl Hood, NRC LPM
  • GeneGallagher,NRCRegionIII(I&E)
  • Daniel Gillen, NRC/NRC Geosciences
  • Lyman Hiller, NRC/NRR Geosciences
  • Ronald Cook, NRC Resident Inspector 1

1 1

  • Present during both the 12/3/78 site tour and the 12/4/78 meeting.

f i i 1 I N' .) l + -r .,g r-p

) 4 / 3 i i ~,. '. Sastesure L ./ /

SUBJECT:

CPCo Midland Plant Units 1 & 2 4 , {;j

J Diesel Cenerator Building JAN 121979

( Meeting with NRC at Midland ,s k 4 DATE: ? December 4,1978 1, p Y AGENDA i ( I. Introduction by CPCo I II. History by Bechtel (N. Swanberg) a. Plant description b. Settlement monitoring prograa' Brief history of site fill placement c. d. Settlement of Category 1 structure 4 - e. Settlement of diesel generator building and pedestals f. Review settlement data and drawings (SK-C-620/623) .g. _ Consultants 1 III. Soil Exploration by Bechtel (S. Afifi) a. Soil borings { b. Dutch cone penetrations c. Laboratory tests i d. Possible causes i 1 \\- IV. Consultant's Recommendation by Dr. R.B. Peck and 1 1 C.J. Dunnicliff \\. ^ a. ,Preload b. Instrumentation 'I V. Status report by Bechtel (B.C. McConnell)- a. Activities completed i b. Activities in progress c. Activities planned for future 1) Corrective action 2) FSAR conformance VI. Schedule by Bechtel (P. Martinez) i 4 a. Overall project b. Impact on project schedule j c. Schedulu for remedial measures i [ ( s--. i u a + e_

ih ' D, VII. Responses to open items in NRC Inspector's report } [ dated 11/17/78 by Bechtel (B. Dhar) JAN 121979 i a. . Responses to Callaghar's concerns: f 1) Conflict between FSAR Table 2.5-14 and ( Table 2.5-10 regarding fill material description

2), Conflict between FSAR Table 2.5-21 and Specification C-210 regarding required number of passes for compaction 3)

FSAR Section 3.8.5.5 - expected settlement 4) Conflict between FSAR Figure 2.5-47 and project' drawing regarding foundation elevation } 5) Conflict in Specification C-210 regarding compactive effort in test method 6) Conflict between consultant's recommendation and Specification C-210 regarding lift thickness 7) + 2Z tolerance in moisture content permitted j .in Spscification C-210 8) Cracks in the building structure b. FSAR Question 362.2 (Section 2.5.4.5.1) VIII. Closing Comments by CPCo I i ( s / I h " 1 at:- s t. ) 1 s 4 O 3 y. I L.

~~~ ~

  • g g. x 4 g 9 cci_,

Ay SHH AiT, Og I. ~ .t(Oc (bmi

  • h,.

hg '#jm y.y'o,t, UNITED STATES 3 3' N 3 0'M i LEAR REGULATORY COMMISSION N b, /b' ~!. msmuoros. o. c. mss D.N 6 A

- -------.. ~. - _. f B&t

%, * * *. +' $N[ MAR :31 1980 1 1"' Id M ljil.i. j rG : MG-K' Docket Nos.: 50-329/3 _.9 ~ j I! j i.' I [I. ~ ).,/ Cet OeA (f y(f 1

I !

jg gg\\ i c-APPLICANT: Consume sPowe,fCompany il ,y FACILITY: Midland P1 , Units 1"& 2 - -~~----------.___i_. _... '. _. ;I t !:

SUBJECT:

SUMMA 0F FEBRUARY 27 & 28, 198 EETING AND SITE" TOUR WITH CONS TANTS TO REVIEW SOIL SE EMENT On February 27 and 28,1980, the NRC staff and three organizations recently acquired to support the staff safety review of geotechnical and interfacing matters, met with Consumers Power Company (the applicant), Bechtel and Bechtel consultants at the site for Midland Plant, Units 1 & 2. The three organizations supporting the staff review are the U. S. Army Corps of Engineerr, Energy Technology Engineering Centar, and U. S. Naval Surface Weapons Center. The purpose of the visit was to r.eview and observe site backfill deficiencies and effects. This was the initial visit for the staff's consultants and the meeting was held to assist these consultants with their review of existing documentation on the background, remedial work and present status of this matter. Meeting attendees are listed in Enclosure 1. The information reviewed at this meeting is contained in Amendment 72 to the s Midland FSAR, December 19, 1979, for which referenced material is forwarded in two volumes by the applicant's letter of February 11, 1980. One of the volumes entitled "10 CFR 50.55(e), In'.erim Reports, Settlement of Diesel Generator Foundations and Building," consists of the 10 CFR 50.55(e) reports sent by the applicant to the staff's Office of Inspection and Enforcement from November 7, 1978 through September 5, 1979. The other volume, entitled " Responses to NRC Requests Regarding Plant Fill," consists of the applicant's 10 CFR 50.54(f) responses to the Office of Nuclear Reactor Regulation submitted April 24, 1979 through November 13, 1979. These documents represent the applicant's reports upon which the staff's order of December 6,1979 requiring modification of the construction permits is based. The meeting also included a preview of information to be contained in Revision 5 to the applicant's responses in the latter volume intended for submittal about the end of February, 1980. Revision 5 will include responses to the staff's supplemental requests of November 19, 1979. Only information not contained in these documents is included in this meeting summary. In opening ren rks, Mr. G. Keeley announced that Consumers Power Company has elected to defer all remedial work on inadequately supported structures until acceptance of the proposed work is received from the staff. This action is ph M~ I [W3A .....n*\\7t' $E 0 l g V WA_> 6 i ./ l l -,___..-,n-

  • ~ ~ ~ ~ ~

d MAR 311980 2-s voluntary on the applicant's part since the effective date for the staff's December 6,1979 order is to be established by the Hearing Board pursuant to 10 CFR 2.204. The basis for this decision was said to be to preclude potential loss of revenue associated with expenditures for which staff approval has not been granted. The staff observed that this was a prudent decision, particularly in view of the significant slip in construction completion projected by Bechtel and currently under review by the applicant and due to other causes, principally the TMI-2 accident. Presentations were also given by Bechtel consultants. Mr. C. H. Gould described the procedure for placement of caissons beneath the electrical penetration area (i.e., wing walls) of the Auxiliary Building and beneath the Feedwater Isolation Valve Pit area. Mr. M. T. Davisson described the procedure for placement of piles to support the northern portion of the Service Wster Building. Dr. A. J. Hendron, Jr. reviewed the preloading program completed for the Diesel Generator Building and discussed why the preload option was elected in lieu of other possiblo corrective alternatives. Dr. R. B. Peck sumarized the recomendations i of the Bechtel consultants and emphasized that the preloading option is con-j sidered to eliminate the need for any further testing or measurements as a basis for establishing confidence for future settlement potential of the Diesel Generator Building. A sumary of these discussions by the Bechtel consultants will be submitted as an amendment tn the FSAR. During the meeting, references were made to certain information and reports which have not been made available to the NRR staff, although some of these have been examined by I&E through the audit mechanism. Examples include: i 1. Some of the figures listed in the drawing sumary for the interim reports to MCAR #24 which are not included with the compilation of reports forwarded by the applicant's letter of February 11, 1980, even after noted figure replacements and redundancy are taken into account. 2. Installation details of each piezometer used to monitor pore water pressures during the preload program (e.g., type and actual elevations of installed piezometers, backfill materials and zone thickness). 3. Reports, meeting sumaries, or other written comunications with or by consultants recomending or supporting remedial measures for structures and utilities located upon or in questionable soils. 1 4. Reports of the evaluation (e.g., bases, procedure, execution and results)of the initial qualification and subsequent requalification of compaction equip-ment. 5. The report " Tank Farm Investigation; Midland Units 1 & 2," issued October, 1979. \\ n.

MIEI O 1 I 5 o ~~ The staff noted that such documents as above are needed by its consultants for their independent assessment of the adequacy of the proposed remedial measures and requested that these be made publicly available. The applicant indicated a reluctance to this end, and noted that these were available through the I&E audit mechanism. The staff will issue a formal request for these documents. The staff also noted that the boring logs provided in Appendix 2A of the FSAR did not reflect those borings associated with piezometer installation; the applicant i , replied that these would be added. 1 Site tours were provided in groups based upon the following engineering disciplines: (1)Geotechnical,(2) Structural,(3) Mechanical,and(4) Hydrologic. During the tour the Corps noted that except for the use of temporary blocks, the service water pipe would otherwise be in direct contact with the base of the penetration through the northern wall of the Service Water Building. It is postulated that this results from the more rapid settlement of the buried pipe relative to the building's-cantilevered settlement. The Corps emphasized that special attention should be given this area to avoid stressing the pipe at the penetration, particularly during pile driving and af ter attachment.of the piles to the structure. The staff noted that the presentation by Mr. C. H. Gould included the specification of some quantitative criteri: f.o be applied during the remedial action for the Auxiliary Building. The staf: asked if similar criteria were specified by the 1 other Bechtel consultants, but was advised that these other criteria were more i of a qualitative, subjective nature. The staff also requested the applicant to submit a description'of' the services to be performed by consultants R. B. Peck, A. J. Hendron, 'Jr., C. H. Gould and M. T. Davisson through the completion of construction on the remaining-remedial fixes. This description should identify the extent cf continued involvement of the consultants in overseeing construction operations and in evaluating the effectiveness of completed fixes for which they have provided major design input, d.lk u ' Darl S. Hood, Project Manager Light Water Reactors Branch No. 4 Division of Project Management

Enclosures:

1. Attendees 2. Agenda ccw/ enclosures: See next page. l \\ O

Consumers Power Company f t ccs- ,/ ' Michael I. Miller, Esq. Mr. S. H. Howell Isham, Lincoln & Beale Vice President Suite 4200 Consumers Power Company i One First National Plaza 212 West Michigan Avenue Chicago, Illinois 60603 Jackson, Michigan 49201 Judd L. Bacon, Esq. Managing Attorney Consumers Power Company 212 West Michigan Avenue i Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers: Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq. ' One IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711 Sumerset Drive Midland, Michigan 48640 ) Frank J. Kelley, Esq. Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Mr. Wendell Marshall Route 10 Midland, Michigan 48640 , Grant J. Merritt, Esq. Thompson, Nielsen, Klaverkamp & James 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 Mr. Don van Farowe, Chief Division of Radiological Health Department of Public Health P. 0. Box 33035 l Lansing, Michigan 48909 i ( l

Consurers Poset Corrany q ces (centinued): l Pesident Inspector / Midland NPS '~ c/o U.S. Nuclear Regulatory Commission P. O. Box 1927 Midland, Michigan 48640 William J. Scanlon, Esq. 2034 Pauline Boulevard Ann Arbor, Michigan 48103 Commander, Naval Surface Weapons Center ATTN: P. C. Huang G-402 White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center P. O. Box 1449 Canoga Park, California 91304 Mr. William Lawhead U. S. Corps of Engineers NCEED - T 477 Michigan Avenue 7th Floor Detroit, Michigan 48226 f .e 6 h/ l

. =. i } ENCLOSURE 1 g ATTENDEES ss \\ 5 Consumers Power Bechtel Consultants C. S. Keeley Harris Burke R. 8. Peck T. C. Cooke Sherif Afifi A. J. Hendron, Jr. T. Thiruvengadam Don Kiat C. H. Could U. E. Horn 8I"*1 Dh*' N T* D*'I*" Bill Paris Julius Rote Jim Wanseck Karl Wiedner John Rutgera Lynn Curtia Al Boos Chuck McConnel Walter Ferris NRC US Corp of Engineers _gggt L. Heller N. Gehring W. P. Chen J. Grundstrom . J. Brammer J. Ka,ne W. Otto A. Cappucci W. Lawhead F. Rinaldi P. Nadala R. Conzalis J. $1mpson ( D. Hood J. Norton O. Callagher R. Cook R. Erickson US Navy Weapons Center P. Huang J. Hatta I 8 l y e e e

ENCLOSURE 2 AGENDA FOR.. MEETINC WITH NRC ON MIDLAND PLANT FILL STATUS AND RESCLUTION February 27 & 28, 1980 Midland Site

1.0 INTRODUCTION

C. Xeeley 2.0 PRESENT STATUS OF SITE INVESTICATIONS T. Cooke 9 2.1 Meetings with Consultants and Options Discussed (Historical) ' 2.2 Investigative Program A. ' Boring Program , 3. Test Pits C. Crac.k Monitoring and Strain causes D. Utilities 2.3 Set'tlement A.' Area Noted 5. Preload , C. Instrumentation 3.0 WORK ACTIVITY UPDAfr J. Wansock j 3.1 Susanary of work activities and settlement surveys for all Category I structures and facilities founded partially or totally on fill 4.0 REMEDIAL WORK IN PROGRESS OR PLANNED (Q4,12, 27, 31, 33 6 35)

8. Afifi

/ k 4.1 Diesel Generator Structures 4.2 Service Water Pump Structures 4.3 Tank Farm 4.4 Diesel 011 Tanks 4.5 Underground Facilities 4.6 Aurillary Sullding and FW 1 solation Valve Pits 4.7 Liquefaction Potential 5.0 EVALUATION OF PIPING (Q16, 17, 18, 19 & 20) D. Riat 6.0 DEWATERINC (Q24)

5. Paris 7.0 ANALYTICAL INVESTICATION B. Dhar a

7.1 Structural Investi$ation (Q14, 26, 28, 29,30 & 34) 7.2 Seismic Analysis (Q25) q *,, /g-7.3 1' Structural Adequacy with Respect to PSAR, FSAR, etc. ,7 ... ~ , 4.0 SITE TOUR All ? 9.0 CONSULTANTS SUtttARY Pech/Hendron/ Gould/Davisson '( .0 DISCUSSION All t.- A- .m.

.6 Cw(( CRcdt) d- = ~ ~ ma =~ g 8o 1:

m....

o, uni t til' T AT Es g -l3 j NUCLE All f:r.GUL A i Oily CO'..*.HSSION " j. j w.umtmin 4. o. c. ac:,a f:

  1. ./,/

(, k Decen,ber 7,19/9 Ivan W. Suith, Esq. lte. Gustavo A. Linenberger Atcalc Safety and Licensing Geard Atomic Safety and Licensing Board U.S. liuclear Regulatory Counission U.S. f:uclear Regulatory Co nission Washington, D. C. 20555 Uashington, D. C. 20555 Dr. Frederick P. Cowan 6152 l1. Verde Trail Apt. B-125 l Boca Raton, Florida 33433 In the Itatter of C0:lSU:tERS POWER CC"PAfiY (Ilidland Plant, Units 1 and 2) DocLet flos. 50-329 and 50-330 10 eratino Licenses _fgceedM 1 l Gan'lcmen: As -a art aware, certain cententions admitted in this proceedin.) concer ti excessive settling of the diesel generator building. The flRC Staff, pursuant to 10 CFR 50..4(f), has been requesting detailed information concerning the matter from the Applicarit, Consumers Power Company. The tiRC Staff 1,3s concluded that the information supplied to date provides insufficient justification of accertance criteria which should be applied to determine whether Consumers' proposed re-medial actions are sufficient. Accordingly, th't director of the Office of Inspection and Enforcement and the director of the Office of !!uclear Reactor Regulation have jointly issued the enclosed " Order Itodifying Construction Pern.* s". Attached to the Order are two notices of violation which describe items of non-conpliance also related to the soil settlement r.atter. Sinscroly, J)f-.J~~hy .f (]L! p'.:.v William J.

Irstead Enclosure as stated Counsel for flRC Staff cc (w/ encl.):

Frank J. Kelley ftyron M. Cherry, Esq. lis,itary Sinclair flichael 1.11111er. Esq. Atcmic Safety & Licensing Coard Panel / Atomic Safety & Licensing Appeal Panel Docketing and Service Section Judd L. Bacon Esq. Le de

i. I; all I

fb~bb b ~ P.!. Davie.. Esc.

j.. l pa nee,s ,s ),, UNITED STATES NUCLEAR REGULATORY COMMISSION t-a 3" I wAswisoTom.o.c.nosss k 8 lL h..... December 6,1979 I Docket Nos. 50-329 l 50-330 ~ Consumers Power Company ATTN: Mr. Stephen H. Howell 1 Vice President 1945 West Parnall Road Jackson, MI 49201 I Gentlemen: 1 I l This letter transmits to you an Order Modifying Construction Per.t.its No. CPDR-81 and No. CPPR-82. This action is being taken as a result of findings by inspectors from Region III, Office of Inspection and Enforcement made j during the period of October 1978 to January 1979, and the conclusions of the NRC staff after reviewing responses to the 10 CFR 50.54(f) request of March 21,M 1979, regarding the proposed remedial work under and around safety-related structures and systems at the site, some of which is currently underway. The Order pertains to the problems associated with the soil foundation materials i at the site, l l ( As part of' the-Order there are two Notices of Violt'. ton. The first Nothe of l Violation is Appendix A which contains information concerning four infractions with several examples, all of which relate to the soil foundation problems. i The second Notice of Violation, Appendix 8, contains information concerning an item of noncompliance which was determined to be a material false statement. Actions that Consumers Power Company may take as a result of this Order are described in the Order. l Sincerely, Sincerely, 2 s ( Edson G. ase Victor Steflo, r. Acting Director Director Office of Nuclear Reactor Of fice of Inspection i Regulation and Enforcement

Enclosures:

1. Order Modifying Construction Permits, CPPR-81 and CPPR-82 2. Appendix A 3. Appendix 8 ( ' , 1 t-' CERTIFIED Mall. KETDT f RECEIPT REQUESTED m f), ~ .n AA/_ &/ b 7 f f A ,,c. v v v j

i N. UNITED STATES OF AMERICA e NUCLEAR REGULATORY COMMISSION s = i In the Matter of ) ) CONSUMERS POWER COMPANY ) Docket No. 50-329 (Midland Nuclear Power Plant, ) 50-330 Units 1 and 2) ) ORDER M00!FYING CONSTRUCTION PERMITS i 1 The Consumers Power Company (the Licensee) is a holder of Construction Permits No. CPPR-81 and No. CPPR-82 which authorize the construction of two pressurized I water reactors in Midland, Michigan. The construction permits expire on October 1,1981 and October 1,1982, for Unit 2 and Unit i respectively. h II On August 22, 1978, the Licensee informed the NRC Resident Inspector at the Midland site that unusual settlement of the Diesel Generator Building had occurred. The Licenses reported the matter under 10 CFR 50.55(e) of the Commission's regulations by telephone on September 7,1978. This notification was followed by a series of interim reports dated September 29, 1978, November 7,1978, December 21, 1978, January 5,1979, February 23,1979, April 3,1979, June 25, 1979, August 10, 1979, September 5,1979, and November 2,1979. Following the September 1978 notification, inspectors from the Region !!!, Office of Inspection and Enforcement, conducted an investigation over the period of October 1978 throu2h January 1979. This tavastigation revealed a breakdown *in quality assurance related to soil construction activities under and around safety-related structures and systems in that (1) certain design and construction specifications related to foundation-type material properties f }] lnOOWI?

c 2-m ~ and compaction requirements were not followed; (2) there was a lack of clear I direction and support between the contractor's engineering office and construc-tion site as well as within the contractor's engineering office; (3) there was a lack of control and supervision of plant fill, placement activities which contributed to inadequate compaction of foundation material; (4) corrective - action regarding noncomformances related to plant fill was insufficient or inadequate as evidence by repeated deviations from,saggiflgation requirements; f and (5) the FSAR contains inconsistent, incorrect, and unsupported statements-with respect to foundation type, soil properties and settlement values. The j details of these findings are described in the inspection reports 50-329/78-12, 50-330/78-12 (November 14, 1978) and 50-329/78-20, 50-330/78-20 (March 19, 1979).which were sent to the Licensee on November 17, 1978 and March 22, 1979 y . respective)y. The items of noncompliance resulting from the NRC investigation are described in Appendix A to this Order. In addition, as described in Appendix B to this Order, a material false statement was made in the FSAR in that the FSAR falsely itated that 'M11 fill and backfill were placed.according to Table 2.5-9.'! This statement is material in that this portion of the FSAR would have been found unacceptable without further Staff analysis and questions if the Staff had known that Category I structures had been placed in fact on random fill rather than cont.olled compacted cohesive fill as stated in the fSAR. ) As a result of questions raised during the NRC investigation of the Diesel Generator Building settlement, additional information was necessary to evaluate t

) 3-l 7 i (' t the impact on plant safety caused by soil conditions under and around r safety-related structures and systems in and on plant fill, and the Licensee's ] related quality assurance program. On March 21, 1979, the Director, Office of j Nuclear Reactor ' Regulation, formally requested under 10 CFR 50.54(f) of the i Commission's regulations information concerning these matters ?.o determine whether action should be taken to modify, suspend or revoke the construction I 1 l permit. Additional information was requested by the Staf f in letter:, dated l September 11, 1979 and November 19, 1979. The Licensee responded to these letters, under oath,'in letters dated April 24, 1979, May 31, 1979, July 9, 1979, August 10, 1979, September 13, 1979, and November 13, 1979. The Licensee has not yet responded to the November 19, 1979 requests. 6 Several of the Staff's requests were directed to the determination and $stificatio[of acceptance criteria to be applied to various remedial measures taken and proposed by the licensee. Such criteria, coupled with the details of the remedial action, are necessary for the Staff to evaluate the technical adequacy and proper implementation of the proposed action. Jhe information girovided by T.he licensee fails to provide such ' criteria. Therefore, based on - a review of the information provided by the Licensee in response to the Staff questions, the Staff cannot conclude at this time that the safety issues ,, associated with remedial action taken or planned to be taken by the Licensee to correct the soll deficiencies will be resolved. Withouttheresolutionof! these issues the Staff does not have rersonable assurance that the affected safety-related portions of the Midland facility will be constructed and g operated without undue risk to the health anrf ofety of the public.

I, I r-3 g i III Under the Atomic Energy Act of 1954, as amended, and the Commission's { regulations, activities authorized by construction permits or portions thereof' may be suspended should the Commission find information which would warrant sthe Commission to' refuse to grant a construction permit on an original applica-e tion. We have concluded that the quality assurance deficiencies involving the, t ,. s I settlement of the Diesel Generator Building and soil activities at the Midland 1 { site, the false statement'in the FSAR, and the unresolved safety issue concerning the adequacy of the remedial action to correct the deficiencies in the soli j construction under and around safety-related structures and systems are adequate, bases to refuse to grant a construction permit and that, therefore, suspension of certain activities under Construction Permits No. CPPR-81 and No. CPPR-82 is warranted until the related safety issues are resolved. j IV Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50, IT IS HERE8Y ORDERED THAT, subject to Part V of this Order, Construction Permits No. CPPR 81 and No. C'PPR-82 be modified as follows: A (1) Pending the submission of an amendment to the application seeking approval of the remedial actions associated with the soil activities for safety-related structures and systems founded in and on plant fill material and the issuance of an amendment to Construction Permits No. CPPR 81 and r ( e

I e I i l { !% i and No. CPPA 82 authorizing the remedial action, the fo11o' wing activities l are prohibited: (a) any placing, compactir.g or excavating soll materials under or around safety related structures and systems; t l (b) physical implementation of remedial action for correction of soil related problems under and around these structures and systems, j including but not limited to: i i (1) dewetering systems f ('li) underpinning of service water building (iii) removal and replacement of fill beneath the feedwater isolation valv'e pit area (iv) pjacing. caissons at the enda of the evnt11ery building electrical penetration areas (v) compaction and loading activities; (c) construction work in soll materials under or around safety related i i structures and systems such as field installation of conduits and piping. l (2) Paragraph (1) above sha11 not apply to any emploring, sampling, or testing of soll samples associated with determining actual soll properties on f-site which has the approval of the Of rector of Region !!!, Office of Inspection and Inforcement. ' ^ ~ ^^

? V The Licensee or any person whose interest is af fected by this Order may within 20 days of the date of this Order request a hearing with respect to all or any part of this Order. In the event a hearing is rtiquested, the issues to be considered will be: (1) whether the facts set forth in Part !! of this Order are correct; and h (2) whether this Order should be sustained. This Order will become effective on the espiration of the period during which ( a hearing may be requested, or in the event a hearing is requested, on the dato specified in an Order mada following the hearing. FOR Tiit HUCLEAR REOULATORY C0 mil 5510N $1 ' Jh N T @ son G. Case AgG ng Olrector Mi: tor Stello, Jr.. Olrector fDfficeofNuclearReactor Office of Inspect, Ion Regulation and Enforcement Attachm9nts: 1. Appendix A 2. Appendix B Dated t Bethesda, Maryland, this /k day of December, 1979. (

DEC 6 1:79 Accendix A s .m l \\ s NOTICE OF VIOLATION

- Y l

Consumers Power Company Docket No. 50-329 Docket No. 50-330 This refers to the investigation conducted by the Office of Inspection and Enforcement at the Midland Nuclear Power Plant, Units 1 and 2, Midland, Michigan, at your offices in Jackson, Michigan, and at Bechtel Corporation, Ann Accor~; Michigan of activities authorized by NRC License No. CPPR-81 and Noi CPPR-82. Based on the results of the investigation conducted during the period December li, 1978 through January 25, 1979, it appears that certain of i your activities were not conducted in full compliance with NRC require-ments as noted below. These items are infractions. 1. 10 CFR 50, Appendix B, Criterion III requires, in part, that measures shall be established and executed to assure that regulatory requirements and the design basis as specified in the license application for structures are correctly translated into specifications, drawings, procedures and instructions. Also, it provides that measures shall be established for the identification and control of design inter-faces and for coordination among participating design organizations. I CPCo_ Topical Report CPC-1-A, Policy No. 3, Section 3.4 states, in ~ part, "the assigned lead design group or organization (i.e., the N NSSS supplier, A&E supplier, or CPCo) assure that designs and materials are suitable and that they comply with design criteria and regulatory requirements." CPCo is committed to ANSI N45.2 (1971), Section 4.1, which states, _.h in part, " measures shall be established and documented to assure that the applicable specified design requirements, such as a design basis, regulatory requirements... are correctly translated into ~ specifications, drawings, procedures, or instructions." ~ i Contrary to the above, measures did not assure that design bases were included in drawings and specifications nor did they provide for the identification and control of design interfaces. As a ~ result, inconsistencies were identified in the license application and in other design basis documents. Specific examples are set forth below: l 'The FSAR is internally inconsistent in that FSAR Figure 2.5-4B a. s

indicates settlement of the Diesel Generator Building to be on 1

i the order of 3" while FSAR Section 3.8.5.5 (structural accept-l jance criteria) indicates settlements on shallow spread footings (p. 3py t} g)/ L 4 q 4

DEC G 1379 i Appendix A

  • T

.A g ~ ' t, ' founded on compacted fill to be on the order of 1/2" or less. The Diesel Generator Building is supported by a continuous shallow spread footing. l b. The design settlement calculations for the diesel generator and borated water storage tanks were performed on the assumption of uniform mat foundations while these foundations were designed and constructed as spread footing foundations. The settlement calculations for the Diesel Generator Building c. indicated a load intensity of 3000 PSF while the FSAR, Figure 2.5-47, shows a load intensity of 4000 PSF, as actually constructed. d. The settlement calculations for the Diesel Generator Building were based on an index of compressibility of the plant fill between elevations 603 and 634 of 0.001. These settlement values were~shown in FSAR Figure 2.5-48. However, FSAF., Table h 2.5-16, indicates an index of compressibility of the same plant fill to be 0.003. PSAR, Amendment 3, indicated that if filling and backfilling e. operati;,m, cee discontinued during pariods of cold weather, all frozen soil would be removed or recompacted prior to the resump-tion of operations. Bechtel specification C-210 does not specif-h ically include instructions for removal of frozen / thawed compacted material upon resumption of work after winter periods. f. PSAR Amendment 3 indicates that cohesionless soil (sand) would be compacted to 85% relative density according to ASTM D-2049. However, Bechtel specification C-210, Section 13.7.2 required cohesionless soil to be compacted to not less than 80% relative density. 2. 10 CFR 50, Appendix B, Criterion V requires, in part, that activities ~ affecting quality shall be prescribed and accomplished in accordance i i with documented instructions, proceaures or drawings. CPCo Topical Report CPC-1-A, Policy No. 5, Section 1.0 states, in part, that, " Instructions for controlling and performing activities affecting quality of equipment or operation during design, construc-tion and operations phase of the nuclear power plant such as procure-ment manufacturing, construction, installation, inspection, testing ... are documented in instructions, procedures, specifications.. . these documents provide qualitative and quanititive acceptance criteria for determining important activities have been satisfactorily accomplished." N h W y*r em v'

i f j i CEC G 1HS Appendix A, CPCo is commited to ANSI N45.2 (1971), Section 6 which states, in . part, " activities affecting quality'shall be prescribed by documented t instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." a. Contrary to the above, instructions provided to field construc-tion for substituting lean concrete for Zone 2 material did not address the differing foundation properties which would result in differential settlement of the Diesel Generator Building. b. Also, contrary to the above, certain activities were not accom-plished according to instructions ~ and procedures, in that: (1) The compaction criteria used for fill material was 20,000 ft-lbs (Bechtel modified proctor test) rather than a compactive energy of 56,000 ft-lbs as specified in Bechtel Specificatioq C-210, Section 13.7. (2) Soils activities were not accomplished under the continuous supervision of a qualified. soils engineer who would perform in place density tests in the compacted fill to verify that all materials are placed and compacted in accordance with specification driteria. This is required by Bechtel Specification C-501 as well as PSAR, Amendment 3-(Dames f' and Moore Report, page 16). i 3. 10 CFR 50, Appendix B, Criterion X requires, in part, that a program for inspection of activities affecting quality'shall be established i l and executed to verify conformance with the documented instructions,. i procedures and drawings for accomplishing the activity. CPCo Topical Report CPC 1-A, Policy No. 10, Section 3.1, states, in part, that " work activities are accomplished according to approved procedures or instructions which include inspection hold points i beyond which work does not proceed until the inspection is complete. j .or written consent for bypassing the inspection has been received 1 from the organization authorized to perform the inspections."- 4 CPCo is commited to ANSI N45.2 (1971), which states, in part, "A program for inspection of activities affecting quality shall be established and executed by or.for the organization performing the. activity to verify conformance to the documented instructions, 4 procedures, and drawings for accomplishing'the activity." Contrary to the above, Quality Control Instruction C-1.02, the . program for insp rction of compacted backfill issued _on October 18,- ~ 1976, did not provide for inspection hold points -to verify that soil work was satisfactorily accomplished according to documented: instructions. e ~ i i- .) i

v EEC 0 1375 r Appendix A ! 'l 4. 10 CFR 50, Apprndix 8, Criterion XVI' requires, in part, that mea-sures shall be established to assure that conditions adverse to quality such as failures, o?ficiencies, defective material and nonconformances are promptly identified and corrected. In case of significant conditions adverse to quality, measures shall assure i that corrective action is taken to preclude repetition. CPCo Topical Report CPC-1-A, Policy No. 16, Section 1.0 states, in part, " corrective action is that action taken to correct and pre-clude recurrence of significant conditions adverse to the quality of items or operations. Corrective action includes an evaluation of the conditions that led to a nonconformance, the disposition of the nonconformance and completion of the actions necessary to prevent or reduce the possibility of recurrence." Contrary to the above, measures did not assure that soils conditions of adverse quality were promptly corrected to preclude repetition. For example: a. As of January 25, 1979, moisture control in fill material had not been established nor adequate direction given to implement this specification requirement. The finding that the field was not performing moisture control tests as required by specifi-cation C-210 was identified in Quality Action Request 50-40, s L dated July 22, 1977. b. Corrective action regarding nonconformance reports related to plant fill was insufficient or inadequate to preclude repeti-tion as evidenced by repeated deviations from specification requirements. For example, nonconformance reports No. CPCo QF.2.9, QF-52, QE,68, QF-147, QF-174, QF-172 and QF-199 contain numberous examples of repeated nonconformances in the same 4 areas of plant fill construction. i ( s,g

DEC 6 079 APPENDIX B NOTICE OF VIOLATION Consumers Power Company Docket No. 50-329 Docket No. 50-330 This refers to the investigation conducted by the Office of Inspection and Enforcement at the Midland Nuclear Power Plant, Units 1 and 2, Midland, Michigan, at your offices in Jackson, Michigan, and at Bechtel Corporation, Ann Arbor, Michigan, of activities authorized by NRC License No. CPPR-81 and No. CPPR-82. During this investigation conducted on various dates between Dece: Der 11, 1978 and January 25, 1979, the following apparent item of noncompliance was identified. The Midland Final Safety Analysis Report (FSAR) contains the following: Section 2.5.4.5.3, Fi'll, states: "All fill and backfill were placed ) according to Table 2.5-9." Table 2.5-9, Minimum Compaction Criteria, contains the following: Comoaction Criteria ( Zone (1) Soil i " Function Desionation Type Degree ASTM Designation Support of u7" Clay 95% ASTMD155g6T-structures W Sr. - (modified) (1) For zone designation see Table 2.5-10. (2) The method was modified to get 20,000 foot pounds of compactive energy per cubic foot of soil." Section 2.5.4.10.1, Bearing Capacity, states: " Table 2.5-14 shows the contact stress beneath footings subject to static and static plus dynamic loadings, the foundation elevation, and the type of supporting medium for various plant structures." Table'2.5-14, Summary of Contact Stresses-and Ultimate Bearing Capacity for Mat Foundations Supporting Seismic Category I and II Structures, contains, in part; the following: " Unit Supporting Soils Diesel Generator Controlled compacted Building cohesive fill." r v

l o l CIC 6 1373 Appendix B 2-(! ~ This information is false, in that materials other than controlled compacted cohesive fill were used to support the diesel generator building and informa-tion presented concerning the supporting soils influenced the staff review of. the FSAR. i 1 i 1 9 1 ( \\ A l t I e t t I I i 5 I s_..'

h e gnokY h t.[- wieowaU 'o UNITED STATES N8 "( *, ",i NUCLEAR REGULATORY COMMISSION

  • -
  • g 3-.

E WASHINGTON. D. C. 20555 d AUG 9 1979 MEMORANDUM FOR: File FROM: Darl Hood, Project Manager, Light Water Reactors Branch No. 4, DPM

SUBJECT:

NRR COMENTS REGARDING ENFORCEMENT ACTION ON MIDLAND SOIL DEFICIENCIES An April 3,1979 memorandum from J. Keppler to H. Thornburg identified five statements from the FSAR regarding the backfill deficiency at the Midland site which I&E considered to be false, and requested a determination as j to the materiality of these statements. Following receipt of this memorandum by NRR on May 7, 1979, it was distributed to technical review branches for review and a meeting was held August 1 to provide NRR coments. Meeting attendees, listed by Enclosure 1, included both I&E and OELD. A simnary of the NRR coments as to the materiality of the five same-numbered statements of the Keppler memo is given in Enclosure 2. OELD defined " materiality" of FSAR statements. This definition served as the basis for judgments in the meeting. A statement was deemed to be " material" if, not withstanding the fact that it was detected by the I&E investigation, it would or could have an influence upon a safety conclusion of the NRR staff (i.e., if it could have resulted in an improper finding or less probing analysis by the staff). The technical significance and willfullness of any i such false statement is relevant to selection of the specific enforcement action deemed to be appropriate. It was noted that some of the technical reviewers had not yet completed review of some of the relevant background material, and therefore only preliminary i coments could be given at the meeting. A subsequent meeting on or about August 3,1979 was scheduled to confirm or modify these preliminary coments. ~'y;_.v l'/, :. O Darl S. Hood, Project Manager Light Water Reactors Branch No. 4 Division of Project Management

Enclosures:

I i As stated 'I 1 l cc: See next page y M v/mM_ _,/uTV (UT~ i t E a

s cc: All Attendees ^ G. Gower L. Rubenstein S. Varga D. Vassallo W. Olmstead H. Thornburg J. Keppler W. Haass D. Skovholt J. Murray e / / G j-l i 1 l i. i v

\\ i l ENCLOSURE 1 ATTENDEES August 1, 1979 Laker (I&EHQ) ge'. : (I&EHQ) i n (NRR GSB)

eman (OELD)

.lan (OELD) (NRRDPM) r (NRR GSB) J (NRR QAB)

1 (NRR QAB) t (NRRAD:Eng)

I&E HQ) .ski NRRSEB) er NRRSEB)(part-time) NRR LWR #4: Actin (NRR GSB: Chief) g BC) . an 2 [ u j' i' I i .f t I 4

'..l o-f 4_ f. j M~' ENCLOSURE 2 37'~} NRR COMENTS ON APRIL 3, 1979 KEPPLER MEMORANDUM l. This statement is considered by NRR to be material; the fact that the Midland fill is of the wrong type (random fill verses structural fill) and was not sufficiently. compacted is viewed by NRR as the core of the settlement problem. Other findings in the report appear to be subparts of (contributers to) this central problem and NRR suggested consideration be given to combining all five findings. 2. NRR stated that the difference between use of 3.0 KSF and 4.0 KSF for the load density for the Diesel Generator Building calculation would not or did not influence a safety conclusion by the NRR staff, and therefore, was not considered to be " material". Rather, the finding is viewed as an indicator of poor QA performance. 3. NRR stated that the difference between use of 0.001 and 0.003 for the index of compressibility for the Diesel Generator Building calculation would not or did not infuence a safety conclusion by the NRR staff, and therefore, was not considered to be " material." Rather, the finding is viewed as an indicator of poor QA perfomance. 4. NRR recognizes the statements in FSAR sections 2.5.4.10.3.5 and 3.8.4.1.2 regarding the type of mat for the Diesel Generator Building to be inconsistent. However they are not false insofar as they reflect what was actually done. In its review NRR interpretated the use of 41 points '( to represent a mat foundation, whereas FSAR section 3.8.4.1.2 accurately identified the buidling to have continuous footings. The impro manc.e(per calculation is viewed by NRR as an indicator of poor QA perfor-s /4 i . g. ~ 5. This statement is considered to be a subpart of statement 1. It also 1 . appears.to be relevant to poor QA performance. 1 4 I g 6 .t f r l a l \\ + .l 'g.' t a [ l 1 A.- 0 a,Y

  • Q 4

.a.. s .. ~, .~.

t ~ { % w ets 5% D-iA - g(qfo Orcd) E ' ". e ba htCgo e [4

  1. o UNITED STATES

! " m ~,7, NUCLEAR REGULATORY COMMISSION i /3{ - I wAsmNGTON, D. C. 20555 p SEP z 71979 . Docket No. 50-329/a30 MEMORANDUM FOR: George C. Gower, Acting Executive Dfficer for Operations Support, IE FROM: Harold D. Thornburg, Director, Division of Reactor Construction Inspection, IE

SUBJECT:

COMMENTS ON NEEDED ACTION ON MIDLAND ENFORCEMENT PACKAGE RIII transmitted an enforcement package to me dated April 3,1979 and that package was sent to X005 as directcd by J. Davis's menorandum of March 21, 1979. RCI provided coments on the enforcement package in a memorandum dated June 13,1979 (see Enclosure 1) to XOOS for coordination. We have not seen any positions in writing from NRR on the Since that date there have been several meetings (8/1, 8/3 and 8/16) package. 2 which addressed, at least in part,. the questions centering around further action on the enforcement package. The meetings were attended by personnel from NRR, ELD and IE. The various elements necessary to make a finding.on a material false statement were examined.' a. Is the statement false? i l b. Is the statement material? Under what circumstances or in what frame of mind was the statement made c. (willful, deceitful, careless disregard)? i As a resbit of these meetings and the subsequent discussions by telephone with HRR representatives, we are of the opinion that the enforcement action should i be taken on Item 1 of the package as a material false statement in that the fill used-st the site was not the type stated in the FSAR as having been used (random vs engineered structural fill). The NRR conclusions on the other four items were that the statements were not material and indicated " poor QA - t perfonnance" on the part of the licensee. J CONTACT: R. E. Shewmaker. IE 49-27551 e A e x l2 M [ .i -l/pr g n,- v ,---w-,


n, v

n n,- ~,-m,-


r-

---r---- +-m

igf$ x G. C. Gower SEP 2 71979 \\ l Further, it is our opinion that the fact that there are four clear instances of conflicting statements in the FSAR vs what was actually done, is evidence of improper internal coordination and failure on the part of the licensee to assure that accurate infonnatim was being provided in the FSAR. These constitute sufficient facts to make a finding that the material false statement was made in careless disregarti of the facts. This would make the material false statement subject to a civil penalty vs actions allowed under the Administrative Procedures Act for the "seemd chance." We strongly reconnend that XOOS ~ advise RIII-to prepare the enforcement package in this manner and that we proceed quickly on this matter. We understand that 4 there is a reluctance by some in the NRC against finalizing an action on material false statements while the bigger questions of the QA program and work being done at the site as corrective actions which are not yet approved by the NRC are being considered for action. In our opinion, the two matters are distinct and IE should proceed with the initiatim of enforcement action on the false statenent. If you have any questions, plea:;e contact us. i h [ o ~ Harold D. Thornburg / Director 4 Division of Reactor Construction Inspection IE cc: G. W. Reinmuth, IE J. G. Xeppler, RIII T. W. Brockett, IE D. Hood, NRR/ C. E. Norelius, RIII l n. l i: 4 l F .3, I w - y t .,y

t (_ km % l L s.$ * .h. $M b, lUY "5 Io NSo Okul) f $0 UNITED STATES g y-y, g NUCLEAR REGULATORY COMMISSION l

g
y WASHINGTON. D. C. 20555 G * *** /

l OCT 0 41979 Docket Nos. 50-329 50-330 ~ MEMORANDUM FOR: James G. Keppler, Director, Region III FROM: George C. Gower, Acting Executive Officer for Operations Support, IE

SUBJECT:

ENFORCEMENT ACTION RELATED TO MIDLAND DIESEL GENERATOR BUILDING AND PLANT FILL AREAS (A/I F30487H1) This refers to your memorandum to H. D. Thornburg dated April 3,1979. You requested that five items be reviewed to determine whether or not they involved material false statements. Based on several meetings between IE, NRR, and ELD, item 1 in Attachment 1 of your letter is considered a material false statement. Items 2-5 in Attachment 1 are not considered material false statements; these four items should be treated as items of noncompliance as you presented in Attachment 2. The Headquarters review is summarized in a memorandum from H. O. Thornburg dated September 27, 1979; a copy is enclosed. A proposed civil penalty package should be prepared and forwarded to X005 for action. We recommend following the format use in the D. C. Cook case. The letter to the licensee would have three appendices. Appendix A would be a Notice of Violation related to the material false statement. Appendix B would be a Notice of Proposed Imposition of Civil Penalties. Appendix C would be another Notice of Violation specifying the four infractions found during the Region III investigation Based on the information presented, we do not believe that the four infractions to be included in Appendix C meet the civil i penalty criteria and, therefore, would not carry monetary penalties. We understand that you plan to have a meeting at Headquarters in the near future to* discuss other actions that may be taken with regard to the Midland facility. This memorandum closes Action Item F30487H1. s t ,L (.. , du.t George ower, Acting Executive Officer for Operations Support Office of Inspection and Enforcement \\ i 8

Enclosure:

M (See next page) A/ D_- 0r 1 ; "lj()lbJVWJI

)M.:.r-w-1. R.' : James G..Keppler , 9 OCT O1' 1979 s./.m.3

Enclosure:

\\ \\ 1 Memo from H0Thornburg dtd 9/27/7 cc.w/ enclosure: 0.. Thompson, IE G. W. Reinmuth, RCI

0. S. Hood, Nag E,8rockett, X005 d

a e s 4 4 1 m g a. 'e f+ ./ \\ .*V - - - 3 F h 4 e t P Q e s I ? + 8 1 t i

  • e E

-e

  • e t

g i. i 4.... 4',', '.'.e.

  • ET
  • a,>

.c .)i ) e e s. l . n/ n' { ,.

  • g 8*
  • ~

4 /. e e gh

  • r

, l? ?} v, - - -' t.: -

- ~ _ - j

    • r h/t)g(OppfcAt 0 16/f YY S

//e//h. //p[tn9., p/ Y,/ c '; SHM i TW( { 4 UNITED STATES f NUCLEAR REGULATORY COMMISSION f g ( 1 e V*e..N/l wasumam.o.c.aoems 4 E JUN 3 01980 / C f (/ '2AV-3)M e -yf twn ^3 s g, Docket Nos.: 50-329/330 N ll

  • b ut N *-

See: I ~. i Mr. J. W. Cook ~ Vice President i' Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201

Dear Mr. Cook:

i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PLANT FILL We have reviewed your responses to our requests of November 19, 1979 regarding the quality of plant fill, effects and remedial actions result-i ing therefrom. Our review is being performed with the assistance of the U. S. Army Corps of Engineers. We and they find that the results of 1 additional explorations and laboratory testing identified in Enclosure 1 j (Request 37) are needed to support required geotechnical engineering j studies. Details on the extent of these studies will be provided shortly i by separate correspondence. Enclosure 1 is provided in order that you may j initiate planning of_the required explorations in a timely manner. How-4 ever we suggest you await receipt of these further details prior to i physically beginning the explorations. Enclosure 1 (Footnote 4 of Table . p{ / 37-1) also includes requests for advanced notification of the availability of certain samples. As noted in our Request 37 of Enclosure 1, your position in previous I d 1' responses to Requests 5 and 35 not to complete additional explorations, 4,5 1 i sampling and laboratory testing after preloading continues to be unacce F. L dih',) 3 able to us. So that you might better understand our position, we offe Mv the M f )' following observations: e. 4 g fe[g i .+ ! ji d The preload program as completed on the hetero eneous matetial g- 'n 1 ] i' which were placed for the purpose of structura fill is not W ,,,7 [ . L [' f necessarily an improvement, nor does it necessarily produce p h</j[st n tion soils of more unifom engineerina properties, compared o he t e \\d ' 0. soilnerformanciwhichwoulo._ Dave _resultedifthemateria} ad been .c roperly compacteTtMriginal requirements eftstitisnea in ee p yn 6p i 3,, f s Midland PSAR. IJf W.T. 6 T 'h&.- O i J y? c ); To develop reasonable assurance of plant safety, the required studies y'10 ', M$ / are needed to serve ** ma W-aandant verification of the credictions of future settlements and the conclusions of the preload program. 3fe'h'(hn-'1in ^n' n 3vvi; s UV Gl yt'

A g -m- ~ ph y es@, p 9- %e a en h+ a Mr. J. W. Cook JUN 3 01980 ff*" ,,N) )/f he required studies will permit an estimate of total and differential settlement for involved structures and systems following drawdown with the proposed permanent dewatering system. Certain aspects of the preload program, such as the complication d W,I,/ ; L ) introduced by the simultaneous raising of the cooling pond reservoir, G/,2N, presentdifficultiesinourfullacceptanceofyourconclusionoftheg< v preload program. also includes other requests for information which we and the O. S. Anny Corps of Engineers need to continue our review. We would appreciate your response to Enclosure 1 at your earliest opportunity. A partial reply based upon data already available should be submitted rather than to await the results of new borings and tests contained in parts of Enclosure 1. Should you require clarifications of these requests and positions, please contact us. i Sincerely, ' (WNG A.$chwencer,ActingChief Licensing Branch No. 3 Division of Licensing

Enclosure:

As stated cc: See next page I i s '.,/

.-~s l 'I cc: 1.icha el I. Eiller, E sq. !:bam, Linceln & Peale Suite 4200 I First National Plaza Chicago, Illinois 60603 Judd L. Bacon, Esq. Managing Attorney Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 e Mr. Paul A. Perry, Secret * ~ Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq. 1 IBM Plaza j Chicago, Illinois 60611 Ms. Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 Frank J. Kelley, Esq. Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Mr. Wendell Marshall Route 10 Midland, Michigan 48640 Grand J. Merritt, Esq. Thompson, Nielsen, Klaverkamp & James 4444 105 Center i 80 South Eighth Street Minneapolis, Minnesota 55402 e e ) k

w - c s) i cc: Commander, Naval Surface Weapons Center ATTN: P. C. Huang ~ G-402 White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge Manager Facility Design Engineering Energy Technology Engineering Center P. O. Box 1449 Canoga, Park California 91304 Mr. William Lawhead U. S. Corps of Engineers

l NCEED - T 7th Floor 477 Michigan Avenue

) Detroit, Michigan 48226 ~ k af l e a e t I ~~ ,w ( -m L

, s ( \\ ADDITIONAL REQUESTS REGARDING PLANT FILL 36. We have reviewed your response to Request 24 and find that-information from additional boring logs is needed. Provide the boring logs for the following explorations: a. Pull down holes PD-1 thru PD-27 (35 holes that include 8A, 20A, 208, 20C,15A, ISB,15C and 27A) b. LOW-1 thru LOW-14 (14 holes) c. TW-1 thru TW-5 and PZ-1 thru PZ-48 (55 holes) d. 0W-1 thru OW-5 (5 holes) e. TEW-1 thru TEW-8 (8 holes) I The logs should include date and method of drilling, the type and location of samples attempted..Also provide the locations, boring logs and available test data of any exploration completed in 1979 and 1980 which.has not yet been submitted. ) 37. Your position in previous responses to Requests 5 and 35 not to (RSP) complete additional explorations, sampling and laboratory testing following the preload program continues to be unacceptable. We require that you complete as a minimum, the exploration and test-ing program indicated by Table 37-1. 38. Discuss the foundation design for any seismic safety-related piping and conduit connected to or located under the Radwaste Building and Turbine Building where piping and conduit have been placed on plant fill. 1 I .I ,l

e Page 1 cf 2 Table 37-1 Request for Additional Explorations, Samp1tng and Testing U Anticipated Geotechnical N Location M Depth 2/ 5,,pjg,9 Lab Testing Engineering Studies to be Required Diesel Generator !Thrufillanda Classify samples For cohesive soils Bearing Capacity Building minimum of 5' according to C-D (Consolidated-Dralned) Settlement (6 holes along into natural Unified Softs C-U (Consolidated-Undrained) Piping Distortion perimeter) glacial till is Classiffcation Consolidation y Y{t~'/,. lj[9lf,p# hh,'g. System i For sands l i Dralned Direct Shear on l [ ,g both loose & dense speci-l mens Y j Y. Relative Density l} Y h \\' c'er n q, y Auxiliary Buildi (, above Same as above Same as above except 4r founoa tion (2 holes) {' add U-U (Unconsolidated-g 3 [, ign (Vertical and Lateral Load Support) Undrained for cohesive soils -}e ~ Service Wa r as above Same as above l Same as above except con-Pfle Foundation Design (1 hole e 3 j solidation testing would (Vertical and Lateral g,% Structure i taining 1 1 be Ilmited to samples in Su gp t X retaining wall foundations. f etaining Wall Sta y }\\ / Y' ( Settlement. p ~~ gh[. *b'bI, h .hE fJ ca end thru ft 1 ? r cohesive softs t I u tr a minimum of Same as above j !p i Slope Stability 7 + ' into natural C-D (Consolidated-Dralned) f cept hole no. 5residualsoilsexi l C-U(Consolidated-Undrained) Fill compaction adequj'-

  • b

) 5d'/ U-U (Unconsolidated-Undrain d which should extend I hv jl 6 ) to bottom elevation j ') of cooling pond. l(al# o M Y h ['d f i NO{ i v i 9,y/v 3 g g.. - See page 2 e

~..- i Page 2 of 2 Table 37-1 (continued) ( i NOTES: If See attached Figs. 37-1 and 37-2 (or approximate boring l location. Holes to be accurately located in the field to avoid obstructions, underground piping and conduits and slurry trench area. y No boring is to be terminated in loose or soft soils. j 3/ Continuous split spoon sampling using SPT is required. Holes are to be held open using either casing or hollow stem auger. Additional borings to obtain representative undisturbed samples for detailed i laboratory testing should be located at the completion and elevation of the split spoon samplir.g program. The groundwater level should be recorded at the completion of drilling in all borings once the level has stabilized. l 4f Normal classification (e.g., gradation, Atterberty Limits) unit weight and moisture content testing to be perfortned on representative samples from each significant foundation layer. This column pertains to lab testing in addition to the above mentioned tests. It is requested I that at least one week notice be provided to the NRC before opening undisturbed samples to permit on site visual observation by Corps 1 of Engineer representative. 5/ The maximum load should be great enough to establish the straight-line portion of the void ratio-pressure curve. 6f Details on the extent of geotechnical engineering studies to be completed using the results of field and lab testing work will A/ be provided in a separate 1.e.tter. ( l I i i .I e I 1 ~ -. -. ..,,.-.-r.m-----+w ,-,,3- -.,,,---r,-, .r . - - - - +-. -c --r -c

l 2 e ti i i I h+ eh t >j m 1 -r ..m., g w ~ p h 1+ gl /, / ) w /v// 9-o e t 3 l+ l. ,jO. ,j 'g. Lu W,- o - -mr ;2g. , O

-b. 3.n..

. -m s c n 4.- + s l+ c 'n Y

m.. /. #/

4 % us..__ _p o-> g,' O ), / L I U,2 // l ) .g - i...,. .+V'// 3 + f' I [([ I p + 8 I 'j s i-a r +\\ + [+ + y+ I e'l r,1 i 4 I St l'il if -i-;'! jf. i + a n i: 'A.- - y ed l 1J i + .l T +

.au.

I-i i .4 t. 9 s ') + n + I 1 I.:r' i n metiKIEE GKtt3 m %413rf::.N'v i t SS il 1.0 I. .i 1 I i. j.tO e. ~" i. I t 9 9

=*- .= cATE n ueur '.1 - ().. Ti EA COOLIM TOwCR I' 'U..M E%R.4 'M , tar Q (.} ' )., l(l ) . ' ~ .fr' m.. O!LY WASTE STORAGE HYOROGEN s g[g., AND TREATMENT TANKS ,'.. R A0 WASTE BLDG. j g.. n AUXILIARY Sug(OgNG . g., %d PL OC Ae PLOC A R m.. ng>grufu%, g T TANn s truTuRes \\ N ...e. WT I UNIT Z cot 4TAINuCNT CONTt.INf.:CNT ,.?, }' ,.,.j+mCog\\s*""' _ :..,...."2. CDE R--ma i i ... cos 16 2,Cca= ^ TUR9rdE SutLDING ,0 et g COE8 CoE9 cc cto

  • e *
  • a=

S.... - L .. 4-. ..v.. 4 g l .3 f C' .n s. N * -.:. & e. 4 i 0 I o i a 5,. ;t...c $.3. g:y,,w.,l.::- u..].J a i n + t co e is <~ -. ~~;7.t y.- -s x

~

., 2, -s SERVICE WI.TE9 d.s e$ rhERATOR *.-e As .) DESEL PUMP STRUCTURE -g. .( {Qg es -n a..

u. m ouSe CCE l3 +p.ve CHLOR p

eun.oiNG COE R Coe.oENsArE - cetV2 c'RcutArNG STORAGE .*.I VF WATER INTAKE STRUCTURE TANES - c... L

  • ({~IO b N[

h.....'.t-O M oh.s .x i COOLsNG 90NO l I DsESEL GENERATOR FUEL FirJure l37-2 8 Ott STORAGE TANES ,/ M i 8 8 8 i s s e i.,, ,,,m ^^

4 [vCA & kb4 Tl T?;???& f (( A (b*fC.$t H n lf ~ UNITED STATES v VJG 071953 NUCLEAR REGULATORY COMMISSION gslt8 y {. p.tC y' ,g, WASHINGTON. D. C. 20065 {[:[N....t:ui! gg 4g A Copies To: SFH JWC GSK DtS (NJSaari - MEGibbs IL&B Serial File Oh85.16 .-ny Doc Control d JARut gers

201 Karl Weidner DBM/TCC aGINEERS REPORT AND REQUEST FOR ADDITIONAL INFORMATION ILL h

1980 requested the results of additional explorations a needed to support certain geotechnical engineering jd plant fill and associated remedial actions. That tails on the extent of these studies would be provided dence. Enclosure 1 is a letter report of July 7,1980 e U.S. Army Corps of Engineers, and is forwarded to . rps report identifies additional information needed to lems identified in paragraph 3. For purposes of con-i ' ered the subparagraphs of paragraph 4 to be sequential sts on this matter. They have also been marked to .f NRR review. Your reply should reference the revised 1should address the requests as marked to reflect our - e Corps report entitled Liquefaction Potential, is not ..nbering since it represents an evaluation rather than er this evaluation to be tentative at this time since 'determinacion of suitable seismic design input for the -s this matter shortly by separate correspondence. t l I R oc? D GlC# I

AUG 4 1960 Mr. J. W. Cook - _, ) I ile would appreciate your reply at your earliest opportunity. Should you need clarification of these requests for additional information, please contact us. Sincerely, i. WW/6W A. Schwencer, Acting Chief Licensing Branch No. 3 4 Division of Licensing

Enclosure:

COE Letter Report dated 7/7/80 cc: See next page ( x O 4 i %6W b I

\\ cc: Michael I. Miller, Esq. Isham, Lincoln & Beale Suite 4200 1 First National Plaza Chicago, Illinois 60603 Judd L. Bacon Esq. Managing Attorney Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq. 1 IBM Plaza Chicago, Illinois 60611 ) Ms. Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 ( Frank J. Kelley, Esq. Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Mr. Wendell Marshall Route 10 Midland, Michigan 48640 Grant J. Merritt Esq. Thompson, Nielsen, Klaverkamp & Janes 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 i i 9 )

l 2-le nue sota 55108 a - owe, Chief iological Health ablic Health in 48909 lon, Esq. 41evard ' Igan 48103 I ngulatory Cornission

tors Office ir. 48640 I

e W M 's 9

~ S i 3- ? cc: Connander, Naval Surface Weapons Center ATTN: P. C. Huang G-402 White Oak Silver Spring, Maryland 20910 ' Mr. L. J. Auge. Manager Facility Design Engineering Energy Technology Engineering Center P. O. Scx 1449 Canosa, Park, California 91304 Mr. William 1.awhead ? U. S. Corps of Engineers NCEED - T ) 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Ms. Sa-bara Stamiris 5795 N..'iver s Freeland, Michigan 48623 Mr. Michael A. Race 2015 Seventh Street Bay City, Michigan 48706 Ms. Sandra D. Reist 1301 Seventh Street Bay City, Michigan 48706 Ms. Sharon K. Warren 636 Hillcrest Midland, Michigan 48640 Patrick A. Race 1004 N. Sheridan Bay City, Michigan 48706 George C. Wilson, Sr. 4618 Clunie Saginaw, Michigan 48603 Mr.' Carol Gilbert 903 N. 7th Street Saginaw, Michigan 48601 s el o y

~ l ~ 't-s cc: Mr. William A. Thibodeau 3245 Weigl Road Saginaw, Michigan 48503 Mr. Terry R. Miller 3229 Glendora Drive Bay City, Michigan 4S706 S e*'% 3 4 a. s4 w N s ,~. \\ )

DEPARTMENT OF THE ARMY i f.- - esmore oest=ce.coare or==- ENCLOSURE 1 ,,,,,,',,",1. . ( 7 Jm. '680 %&o, 's 3 NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167 Task No.1 - Midland Plant Units 1 and 2, Suhtask No. 1 - Letter Report / e THRU: Division Engineer, North Central. AITN: NCDED-G (James Simpson) TO: U.S. Nuclear Regulatory Commission ATTN: Dr. Robert E. Jackson Division of Systems Safety Mail Stop P-314 Washington, D. C. 20555 The Detroit District hereby submits this letter report with regard to 1. completion of subtask No. I of the subject Interagency Agreement concerning the Midland Nuclear Plant, Units 1 and 2. The purpose of this report is to identify unresolved issues and make recommendations on a course of action and/or cite additional information necessary to settle these matters prior to preparation of the Safety Evaluation Report. g The Detroit District's team providing geotechnical engineering support to 2.the NRC to date has made a review of furnished documents concerning foundations for structures, has jointly participated in briefing meetings with the NRC staff, Consumers Power Company (the applicant) and personnel from North Central Division of the Corps of Engineers and has made detailed site The data reviewed includes all documents received through inspections. Amendment 78 to the operating license request, Revision 28 of the FSAR, Revision 7 to the 10 CFR 50.54(f) requests and MCAR No. 24 through Interim Report No. 8. Generally, each structure within the complex was studied as a separate entity. A listing of specific problems in review of Midland I! nits 1 and 2 follows 3. The issues are unresolved in many instances, for Category I structures. The structures to be addressed because of inadequate or missing information. follow the description of the problem. \\ Inadequate presentation of subsurf ace information from completed a. All structures. borings on ceaningful profiles and sectional views. l l l e

  • p.

/ i 'E' &$$t$$$5L&fgG$[Q&M'&Q]Q:fggg.g g

'l JUL 1980 NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167, Task No.1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report ) i-b. Discrepancies between soil descriptions and classifications on boring logs with submitted laboratory test results summaries. Examples of such discrepancies are found in boring T-14 (Borated water tank) which shows stiff to very stiff clay where laboratory tests indicate sof t clay with. shear strength of only 500 p.s.f. The log of boring T-15 shows stiff, silty clay, while the lab tests show sof t, clayey sand with shear strength of 120 p.s.f. All structures. c. Lack of discussion about the criteria used to select soil samples for lab testing. Also, identification of the basis for selecting specific values for the various parameters used in foundation design from the lab test res ult s. All structures. d. The inability to completely identify the soil behavior from lab testing (prior to design and construction) of individual samples, because in general, only final test values in summary form have been provided. All structures. (1) Lack of site specific information in estimating allowable bearing g pressures. Only textbook type information has been provided. If necessary, bearing capacity should be revised based on latest soils data. All structures on, or partially on, fill. (2) Additional information is needed to indicate the design nethods used, design assumptions and computations in estimating settlement for safety related structures and systems. All structures except Diesel Generator Building where surcharging was performed. e. A complete detailed presentation of foundation design regarding remedial measures for structures undergoing distress is required. Areas of remedial measures except Diesel Generator Building. f. There are inconsistencies in presentation of seismic design information as affected by changes due to poor compaction of plant fill. Response to NRC question 35 (10 CFR 50.54f) indicates that the lower bound of shear wave velocity is 500 feet per second. We understand that the same velocity will be used to analyze the dynamic response of structures built on fill. However, from information provided by the applicant at the site meeting on 27 and 28 February 1980, it was stated that, except for the Diesel Generator Building, higher shear wave velocities are being used to re-evaluate the dynamic response of the structures on fill material. Structures on fill or partially on fill except Diesel Generator Building. 4. A listing of specific issues and information necessary to resolve them. $ f, . Reactor Building Foundation (1), Settlement / Consolidation. Basis for settlement / consolidation of the reactor foundation as discussed in the FSAR assu=es the plant site would l l 's 2 ~MWMNV3C#MNWSWWMM5NNS$$M:GY31kWWNiM981.W

~ 7 JUL 1980 NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167, Task No.1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report l not be dewatered. Discuss and furnish computation for settlement of the Reactor Buildings in respect to the changed water table level as the result of site dewatering <. Include the effsets of bocyancy, which were used in previous calculations, and fluctuations in water table which could happen if the dewatering system became inoperable. i (2) Bearing Capacity. Bearing capacity computations should be l provided and should include method used, foundation design, design assumptions, adopted soil properties, and basis for selecting ultimate bearing capacity and resulting factor of safety. Diesel Generator Building. (1) Se t tlement/ Consolidation. - In the response to NRC Question 4 and 27, (10 CFR 50.54f), the applicant has furnished the results of his computed settlemener due to various kinds of loading conditions. From his explanation of the results, it appears that compressibility parameters obtained by the preload tests have been used to coqute the static settlements. Information pertaining to dynamic response including the amplitude of vibration of generator pedestals have also been furnished. The observed settlement pattern of the Diesel Generator Building indicates a direct correlation with soil types and properties within the backfill material. To verify the preload test settlement predictions, compute settlements based on test results on samples from new borings which we have requested in a separate memo and present the results. Reduced ground water levels resulting from dewatering and diesel plus seismic vibration should be considered in settlement and seismic analysis. Furnish the ecmputation details for evaluating amplitude of vibration for diesel generator pedestals including magnitude of exciting forces, whether they are constant or frequency dependent. (2) Bearing Capacity. Applicant's response to NRC Question 35 (10 CFR 50.54f) relative to bearing capacity of soil is not satisfactory. Figure 35-3, which has been the basis of selection of shear strength for computin. bearing capacity does not reflect the characteristics of the soils under the Diesel Generator Building. A bearing capacity computation should be submitted based on the test results of samples from new borings which we have requested in a separate meno. This information should include method used, foundation design assumptions, adopted soil properties and basis for selection, ultimate bearing capacity and resulting factor of safety. (3) Preload Effectiveness. The effectiveness of the preload should be studied with regard to the moisture content of the fill at the time of preloading. The height of the water table, its time duration at this level, and whether the plant fill was placed wet or dry of optimum would be all important considerations. 3 l n

7 JUL $80 l NCEED-T l SUMECT: Irteragency Agreement No. NRC-03-79-167, Task No.1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report [T (a) Cranular Soils. When sufficient load is applied to granular soils it usually causes a reorientation of grains and movement of particles into more stable positions plus (at high stresses) fracturing of particles at their points of contact. Reorientation and breakage creates a chain reaction among these and adjacent particles resulting in settlement. Reorientation is resisted by friction between particles. Capillary tension would tend to increase this friction. A moisture increase causing saturation, such as a rise in the water table as occurred here, would decrease capillary tension resulting in more compaction. i Present a discussion on the water table and capillary water effect on the granular portion of the plant fill both above and below the water table during and after the preload. (b) Impervious and/or Clay Soils. Clay fill placed dry of optimum would not compact and voids could exist between particles and/or chunks. In this situation SPT blow counts would give misleading information as to strength. Discuss the raising of the water table and determine if the time of saturation sus long enough to j saturate possible clay lumps so that the consolidation could take place that would preclude further settlement. Discuss the preload effect on clay soils lying above the water table (7 feet +) that were possibly compacted dry of optimum. It would appear only limited consolidation from the preload could take place in this situation and the potential for further settlement would exist. Discuss the ef fect of the preload on clays placed wet of optimum. It would appear consolidation along with a gain in strength would take place. Determine if the new soil strength is adequate for bearing capacity. Co u on-S ce he elia 11 o exi in fil an act ni orma ion ar/ E8l8ff2 i er* in ad ti al in a te s de e id r tio an o s) ela iv de ty ois r con at dens cy, o olid ion rop tipt Cnend 67 / 6/30 ouf push A s/80 a s en.h ri a est w uld pp r to e si ble n or er t tfes-at fa or y swe the be e q sti .s. or gs ho be uti w* di ur dc.esi s 1 mpi ta n. (4) Miscellaneous. A contour map, showing the settlement configuration of the Diesel Generator Building, furnished by the applicant at the meeting of 27 and 28 Febr.uary 1980 indicates that the base of the building has warped due to differential settlements. Additional stresres will be induced in the various components of the structure. The applicant should evaluate these stresses due to the differential settlement and furnish the cocputations and results for review. 4 ( ) F + W[4Mkm E h.i. M h /* ( $ d ) Lih k M W k) ? [ 4W Z d 5 7 ( I'

i i i ? JUL 30 keement No. NRC-03-79-167, Task No.1 - Midland Plant Subtask No.1 - Letter Report 11 ding Foundation. acity. A detailed pile design based upon pertinent loped in order to more effectively evaluate the item prior to load testing of test piles. Provide lreferencetotestdataonwhichtheyarebased,and ped to estimate pile design capacity including 'timated maximum static and dynamic loads to be pontribution (DL, LL, OBE, SSE) on the maximum loaded safety against soil failure due to maximum pile load. provide analysis evaluating possible differential cur betvaen the pile supported and and the portion Al till. D*sersbe de om t of fallere on refef

ussesy why Nr#eYaflN. Ji*jnes,**/ / eel o fea tures (e.s beluis,A en 1

g wall adjacent to the intake Li to be* Seismic Category I structure. Evaluate the 7th the service water pumphouse retaining walls and pining wall and the significance of the settlement ant prediction on the safe operation of the Midland fefion owe.ble stresses erraitted by approwed confes. y she skw// o/drett anteel sl%erser induced b s }ysis. Provided the proposed 100 ton ultimate pile ,nved and reasonable margin of safety is available, the iposed for the overhang section of the Service Water .ide the support necessary for the structure under hic inertial loadings even if the soil under the $tructureshouldliquefy. There is no reason to think ?t this time, and the applicant has committed to a load hilecapacity. The dynamic response of the structure, cads for which the structure itself is designed and 1 contained therein, would change as a result of the p. Therefore: 1 trize or provide copies of reports on the dynamic 3 in its old and proposed configuration. For the information on the stiffness assigned to the piles stiffnesses were obtained and show the largest change jt1 response spectra resulting frous the proposed aposed configuration has not yet been analyzed, l 4t are to be performed giving particular attention to i or selectica, of and the range of numerical I to the vertical piles. nr completion of the new pile foundation, in i it No. 6, item 125, Consumers Poser Company menorandum 1 5 t

/ 7 JUL $80 NCIED-T

SUBJECT:

Interagency Agreement No. NRC-03-79 -167 Task,No.1 - Midland Plant Units 1 and 2, Subtask No. 1 - Letter Report \\ dated 13 March 1980, the results of measure ents of vertical applied load and absolute pile head vertical deformation which will be made when the structural load is jacked on the piles so that the pile stiffness can be determined and compared to that used in the dynamic analysis. N. [ Auxiliary Building Electrical Penetration Areas and Feeduater Isolation Valve Pits. (1) Settlement. Provide the assumptions, method, computation and estimate of expected allowable lateral and vertical deflections under static and seismic loadings. (2) Provide the construction plans, and apecifications for underpinning operations beneath the Electrical Penetration Area and Feedwater Valve Pit. The requested information to be submitted should cover the following in sufficient details for evaluation: the to,povery Details of dewatering system (locations, depth, size and capacity (a) A of wells) including the monitoring program to be required, (for example, measuring drawdown, flow, frequency of observations, etc.) to evaluate the performance and adequacy of the installed system. ", (b) Location, sectional views and dimensions of access shaf t and drif t to and below auxiliary building wings. (c) Details of temporary surface support system for the valve pits. bsP Dewatering before underpinning is recommended in order to preclude differential settlement between pile and soil supported elements and negative drag forces. () Provide adopted soil properties, method and assumptions used to l estimate caisson and/or pile design capacities, and computational results. Provide estimated maximum static and dynamic load (compression, uplif t and lateral) to be imposed and the individual contribution (DL, LL, OBE, SSE) on maximum loaded caisson and/or pile. Provide factor of safety against soil failure due to maximum pile load. e(t) Discuss and furnish computations for settlement of the portion of the Auxiliary Building (valve pits, and electrical penetration area) in respect to changed water level as a result of the site devatering. Include the effect of bouyancy, which was used in previous calculations, and fluctuations in water table which could happen, if dewatering system becomes inoperable. (f) Discuss protection measures to be required against corrosion, if piling is selected. 6 - T.v ~N~.+W".W.m KWMci+1gqs-m 3Myg.y.n;.y aq.33 n..,w - -

s I +. 7 JUL 1980 NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167, Task No.1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report m T (h Identify specific information, data and method of presentation to be submitted for regulatory review at completion of underpinning operation. This report should summerize construction activities, field inspection records, results of field load tests on cais' sons and piles and an evaluation of the completed fix for assuring the stable foundatior. % [ Borated Water Tanks. (1) Settlement. The settlement estimate for the Borated Water Storage Tanks furnished by the applicant in response to NRC Question 31 (10 CFR 50.54f) is based upon the results of two plate load tests. conducted at the foundation elevation (EL 627.0%) of the tanks. Since a plate load test is not af factive in providing information regarding the soil beyond a depth more than twice the diameter of the bearing plate used in the test, the estimate of the settlement furnished by the applicant does not i telude the contribution of the sof t clay layers located at depth more than 5' below the bottom of the tanks (see Boring No. T-14 and T-15, and T-22 thru P-26). (a) Compute settlements which include contribution of all the soil layers influenced by the total load on the tanks. Discuss and provide for review the analysis evaluating differential settlement that could ocasr between the ring (foundations) and the center of the tanks. (b) The bottom of the borated tanks being flexible could varp under differential settlement. Evaluate what additional stresses could be induced in the ring beams, tank walls, and tank bottoms, because of the settlement, and compare with allowable stresses. Furnish the computations on stresses including method, assumptions and adopted soil properties in the analysis. (2) Bearing Capacity. Laboratory test results on samples from boring T-15 show a sof t stratum of soil below the tank bottom. Consideration has not been given to using these test results to evaluate bearing capacity information furnished by the applicant in response to NRC Question 35 (10 CFR 50.54f). Provide bearing capacity computations based on the test results of the samples from relevant borings. This information should include method used, foundation design assumptions, adopted soil properties, ultimate bearing capacity and resulting factor of saferv for the static and the seismic loads. Q Underground Diesel Fuel Taak Foundation Design (1) Bearing capacity. Provide bearing capacity computation based on the test results of samples from relevant borings, including method used, foundation design assumptions, adopted soil properties, ultimate bearing capacity and the resulting factor of safety. (2), Provide tank settlement analysis due to static and dynamic loads including methods, assumptions made, etc. \\ "Ot".If-! M yC m w nc. wcmwwmir.,v mm-=.a.m.m m m.m ~_

l 7 Jut. sa h7.EED-T SU3 JECT: Interagency Agreement No. NRC-03-79-167, Task ~No.1 - Midland Plant Units 1 and 2, Subtask No.1 - I.etter Report ) 1 (3) What will be effects of uplift pressure on the stability of the tacks and the associated piping system if the dewatering system becomes inoperable? h, Underground Utilities: (1) Settlement l (a) Inspect the interior of water circulation piping with video j cameras and sensing devices to show pipe cross section, possible areas of crackings and openings, and slopes of piping following consolidation of the P ant fill beneath the imposed surcharge loading. l

(b) The applicant has stated in his response to NRC Question 7 (10 CFR 50.54f) that if the duct banks remain intact af ter the preload progrsa has been completed, they will be able to withstand all future operating loads.

Provide the results of the observations made, during the preload test, to determine the stability of the duct banks, with your discussion regarding their reliability to perform their design functions. (c) The response to Question 17 of " Responses to NRC Requests Regarding Plant Fill" states that "there is no reason to believe that the stresses in Seismic Category I piping systems will ever approach the Code allowable. " We question the above statement based on the followings t Profile 26" - OHBC-54 on Fig. 19-1 shows a sudden drop of approx. 0.2 feet within a distance of only 20 feet. Using the procedure on p.17-2, fb = E(e) = E ( D ) = E ( D ) ( 86 ) 2R 2 g,2 p = 30000 '( 26 ) [ 8(0.2)(12)_] = 130.0 KSI 2 (20x12)' a y g // Q /, -T.::h: =., th; 2. .0(.) ;f.'.;;i l..W5 652.5, - III, Li..;h; 1, ;! J.. 3 J.I'.'" wa. @;;; :h: :::: h;.;.; ! e;;ifh;;h T;;;e; "i" 'n .. 1...-' r:p;t;d n;;1 ;;; ::::::;;. Yet, Table 17-2 lists only 52.5 KSI8" stress for this pipe. This matter requires further review. Please respond to A U, apparent discrepancy and also specify the location of each computed settlement stress at the pipeline stationing shown on the profiles. More than one critical stress location is possible along the same pipeline. (d) During the site visit on 19 February 1980, we observed three instances of *.-hat appeared to be degradation of rattlespace at penetrations of Category I piping through concrete walls as follows: ( 8 w-wwwwwimwmnm.rmaunMIMM.itRi&k%'%RME!B3M2

7 JUL 580 NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167, Task No. 1 - Midland Plant Units 1 and 2. Subtask No.1 - Letter Report ! ]- West Borated Water Tank - in the valve pit attached to the base of the structure, a large diameter steel pipe extended through a steel sleeve placed in the wall. Because the sleeve was not cut flush with the wall, clearance between the sleeve and the pipe was very small-. g-sles* t we.a A k :.% $*s W.w.*a: eauD ehCYee3bd up Service Water Structure - Two of the cervice unter pipes penetrating the northwest wall of the service water structure had settled differentia 11y with respect to the structure and were resting on slightly squashed short pieces of 2 x 4 placed in the bottom of the penetration. From the inclination of the pipe, there is a suggestion that the portions of the pipe further back in the wall opening (which was not , visible) were actually bearing on the invert of the ) opening. The bottom surface of one of the steel pipes had small surface irregularities around the edges of the area in contact with the 2 x 4. Whether these irregularities are normal manufacturing irregularities or the result of concentration of load on this ] temporary support caused by the settlement of the j fill, was not known. These instances are suf ficient to warrant an examination of those penetrations where Category I pipe derives support from plant fill on one or both sides of a penetration. In view of the above facts, the following information is required. (1) What is the minimum seismic rattlespace required between a Category I pipe and the sleeve through which it penetrates a wall? (2) Identify all those locations where a Category I pipe deriving support from plant fill penetrates an exterior concrete wall. Determine and report the vertical and horizontal rattlespace presently available and the l minimum required at each location and describe remedial actions planned as a result of conditions uncovered in the inspection. It is anticipated that the answer to Question (1) can be obtained without any significant additional excavation. If this is not the case, the decision regarding the necessity to obtain information at those locations requiring mejor excavation should be deferra.d until the data fron the other locations have been examined. l [ 9 ~ 4 1 1

  • N

? Yk C. k k hk t* $ k { .h N y e

.. ~ F b 2[ 8 7 jUll360 NCEED-T SU3 JECT: Interagency Agreement No. NRC-03-79-167 Task 'No. 1 - Midland Plant Units 1 and 2, 3Cs:ask No.1 - Letter Report 7g (e) Provide details (thickness, type of materiai etc.) of bedding or cradle placed beneath safety related piping, conduits, and supporting s tructures. Provide profiles along piping, and conduits alignments showing the properties of all supporting materials to be adopted in the analysis of pipe stresses caused by settlement. (f) The two reinforced concrete return pipes which exit the Service Water Pump Structure, run along either side of the emergency cooling water reservoir, and ultimately enter into the reservoir, are necessary for safe shutdown. These pipes are buried within or near the crest of Category I alopes that form the sides of the emergency cooling water reservoir. There is no report on, or analysis of, the seismic stability of post earthquake residual displacement for these slopes. While the limited data from this area do not raise the specter of any problem, for an important element of the plant such as this, the earthquake stability should be examined by state-of-the-art methods. Therefore, provide results of the seismic analysis of the slopes leading to an estimate of the permanent deformation of the pipes. Please provide the following (1) a plan showing the pipe location with respect to 'other nearby structures, slopes of the reservoir and the coordinate system; (2) cross-sections shosing the pipes, normal pool levels, slopes, subsurface conditions as interpreted from borings and/or logs of excavations at (a) a location parallel to and about 50 ft from the southeast outside vs11 of the service water pipe structure and (b) a location where the cross section will include both discharge structures. Actual boring logs should be shown on the f 3 profiles; their offset from the profile noted, and soils should be described using the Unified Soil Classification Systen; (3) discussion of available shear strength data and choice of strengths used in stability analysis; (4) determination of static factor or safety, critical earthquake acceleration, and location of critical circle; (5) calculation of residual movement by the method presented by Newnark (1965) or Makdisi and Seed (1978); and (6) a determination of whether or not the pipes can function properly af ter such movements. h. Cooling Pond. (1) Emergency Cooling Pond. In recognition that the type of embankment fill and'the compaction control used to construct the retention dikas for the cooling pond were the same as for the problem plant fill, we request reasonable assurance that the slopes of the Category I Emergency Cooling Pond (baf fle dike and main dike) are stable under both static and dynamic loadings. We request a revised stability analysis for review, which will include identification of locations analyzed, adopted foundation and enhanknent conditions (stratification, seepage, etc.) and basis for selection, adopted soil properties, method of stability analysis used and resulting factor of safety with identification of sliding surfaces analyzed. Please address any potential impact on Category I pipes near the slopes, based on the results of this stability study. Recommendations for location of new exploration and testing have been provided in a separate letter. i 10 4 j

c-v musso ~ / NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167, Task No. 1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report (2) Operating Cooling Pond. A high level of safety should be f required for the remaining slopes of the Operating Cooling Pond unless it can be assured that a failure will nots (a) endanger public health and properties, (b) result in an assault on environment, (c) impair needed Recommendations for locations of new borings and~ 1aboratory emergency access. tests have been submitted in a separate letter. These recommendations were made on the assumptions that the stability of the operating cooling pond dikes should be demonstrated. I7. Site Dewatering Adequacy. (1) In order to provide the necessary assurance of safety against liquefaction, it is necessary to demonstrate that the water will not rise above elevation 610 during normal operations or during a shutdown process. The applicant has decided to accomplish this by pumping from wells at the In the event of a failure, partial failure, or degradation of the site. , dewatering system (and its backup system) caused by the earthquake or any

  • other event such as equipment breakdown, the water levels will begin to rise.

Depending on the answer to Question (a) below concerning the normal operating water levels in the immediate vicinity of Category I structures and pipelines j founded on plant fill, dif ferent amounts of time are available to accomplish repair or shutdown. In response to Question 24 (10 CTR 50.54f) the applicant states "the operating groundwater level vill be approximately el 595 f t" (page 24-1). On page 24-1 the applicant also states "Therefore el 610' is to be used in the designs of the dewatering system as the maximum permissible groundwater level elevation under SSE conditions." on page 24-15 it is stated that "The wells will fully penetrate the backfill sands and underlying natural sands in this area." The bottom of the natural sands is indicated to very f rom elevation 605 to $80 within the plant fill ares according to Figure 24-12. The applicant should discuss and furnish response to the following questions: (a) Is the normal operating dewatering plan to (1) pump such that the vster level in the wells being pumped is held at or below elevation 595 or (2) to pump as necessary to hold the water levels in all obserystion wella acar Category I Structures and Category I Pipelines supported on plant fill at or below elevation 595, (3) to pump as necessary to hold water levels in the wells mentioned in (2) above at or below elevation 610, or (4) something else? If it is something else, what is it? (b) In the event the water levels in observation wells near Category I Structures or Pipelines supported on plant fill exceed those for normal operating conditions as defined by your answeer to

  • Question (a) what action will be taken? In the event that the water level in any of these observation wells exceeds elevation 610, what action will be taken?

11 .M,"; m m T w w,s.ggg.. r, v ,,y gy;,,7z,,g

1 k. S0 T.CIED-T S3JICT: Interagency Agreement No. NRC-03-79-167 Task No.1 - Midland Plant Units 1 and 2. Subtask No.1 - Letter Report / (c) Uhere will the observation wells in the plant fill area be ( located that will be monitored during the plant lifetime? At what depths will the screened intervals be? Will the combination of (1) screened interval in cohesionless soil and (2) demonstration of ticaly response to changes in cooling pond level prior to draudown be made a condition for selecting the observation wells? Under what conditions will the alarm mentioned on page 24-20 be triggered? What will be the response to the alar:n? A worst case test of the completed permanent dewatering and groundwater level monitoring systems could be cenducted to determine whether or not the time required to accomplish shutdown at d cooling is available. This could be done by shutting off the entire devatoring system when the cooling pond is at elevation 627 and

stermining the water lavel versus time curve for each' observation well. The dest should be continued until the water level under Category I structure, those foundations are potentially liquefiable, reachos elevation 610 (the uor=al water level) or the sun of the time intervals allotted for repair and the tira interval needed to accomplish shutdown (should the repair prove casuccessful) has been exceeded, whichever occurs first.

In view of the heterogeneity of the fill, the likely variation of its permeability and the necessity of making several assumptions in the analysis which was presented in the applicant's response to Question 24a_, a full-scale test should give more reliable information on the available time. In view of the above the applicant should furnish his response to the following If a dewatering system failure or degradation occurs, in order to assure that the plant is shutdown by the time water level reaches elevation 610, it is necessary to initiate shutdown earlier. In the event of a failure / of the dewatering system, what is the water level or condition at which shutdown will be initiated? How is that condition determined? An acceptable

ethod would be a full-scale worst-case test perforced by shutting off the entire dewatering systen with the cooling pond at elevation 627 to determine, at each Category 1 Structure deriving support fron plant fill, the water level at whica a sufficient time window still remains to accomplish shutdown before the water rises to elevation 610.

In establishing the.a,roundwater level or condition that will trigger shutdown, it is necessary to account for normal surface water inflow as well as groundwater recharge and to assume that any additional action taken to repair the devatorit.;t system, beyond the point in eine when the trigger condition is first reachei, is unsuccessful. 1 (2) As per applicant response to NRC (pestion 24 (10 CTR 50.54f) the design of the permanent dewaterits system is basal upon two major findings: (1) the granular backfill materials are in hydraulic connection with an underlying discontinuous body of' natural sand, and (2) seepage from the cooling pond is restricted to thu intake and puep structure area, since the plant fill south of Diesel Generator Poilting is an ef fective barrier to the inflow of the cooling pond water. However, soil profiles (Tigure 24-2 in the "Rasponse to NRC Reguests Regarding *1snt Till"), pumping test time-drawdown graphs (Tigure 24-1 ), and plotted cones of influence (Tiscre 24-15) indicate that south of Diesel Generator Building, the plant fill tasterial adjdcent to 12 ) 'M Nww-r hhhhh A, 4,

I M $80 NCEED-T

SUBJECT:

Intersgency Agreement No. NRC-03-79-167 Task No.1 - Midland Plant ] Units 1 and 2, Subtask No.1 - Letter Report the cooling pond is not an effective barrier to inflow of cooling pond water. ne estimated permeability for the fill material as reported by the applicant is 8 feet / day and the transmissivities range. from 29 to 102 square feet / day. Evaluate and furnish for review the recharge rate of seepage through the fill materials from the south side of the Diesel Generator Building on the permanent dewatering system. This evaluation should especially considar the recovery data from PD-3 and complete data from PD-5. (3) The interceptor wells have been positioned along the northern side of the Water Intake Structure and service water pump structures. The calculations estimating t1 total groundwater inflow indicate the structures serve as a positive cutof f. However, the isopachs of the sand (Figures 24-9 and 24-10) indicate 5 to 10 feet of remaining natural sands below these structures. The soil profile (Figure 24-2) neither agrees nor disagrees with the isopachs. The calculations for total flow, which assumed positive cutoff, reduced the length of the line source of inflow by 2/3. The calculations for the spacing and positioning of wells assumed this reduced total flow is applied along the entire length of the structures. Clarify the existance of seepage below the structures, present supporting data and calculations, and reposition wells accordingly. Include the supporting data such as draudown at the interceptor wells, at midway location between any two consecutive wells, and the increase in the water elevations downstream of the interceptor wells. The presence of structures near the cooling pond appears to have created a situation of artesian flow through the sand layer. Discuss why artesian flov was not considered in the design of the dewatering system. (4) Provide construction plans and specification of permanent dewatering system (location, depths, size and capacity of wells, filtarpack design) including required monitoring program. The informatico furnished in response of NRC Question 24 (10 CTR 50.54f) is not adequate to evaluate the adequacy of the system. (5) Discuss the ramifications of pluggin2 or leaving open the weep holes in the retaining wall at the Service Water Building. (6) Discuss in detail the maintenance plan for the deustering syste:n. (7) What are your plans for monitoring water table in the control tower area of the Auxiliary Building? (b) What measures will be required to prevent incrustation of the ' pipings of the dewatering systes. Identify the controls to be required during plant operation (measure of dissolved solids, chemical controls). Provide basis for established criteria in view of the results shown on Table 1, page 23 of tab 147. 1 j (' 13 j ~'..- m n= -s.

NCEED-T SUS.iECT: Interagency Agreement No. NRC-03-79-167, Task No.1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report (9) Upon reaching a steady state in dewatering, a groundwater survey I should be made to confirm the position of the water table and to insure that no perched water tables uist. Dewatering of the site should be scheduled with a sufficient lead time before plant start up so that the additional settlement and its effects Settlement should be closely monitored (especially on piping) can be studied. during this period. pela ns fee condestiong this youndwsin fuYvey. froyfje your

j. Liquefaction Potential.

An independent Seed-Idriss Simplified Analysis was performed for the fill area under the assumption that the groundwater table was at or below For 0.19 3 peak ground surf ace accceleration, it was found elevation 610. that blow counts as follows were required for a. factor of safety of 15: Minimum SPT Blow Count *I Elevation For T.S. = 1.5 ft 610 14 605 16 600 17 19 595 The analysis was considered conservative for the following reasons (a) no account was taken of the weight of any structure, (b) liquefaction criteria for a magnitude 6 earthquake were used whereas an NRC memorandum of 17 Mar 80 l' considered nothing larger than 5.5 for an earthquake with the peak acceleration level of 0.19 g's, (c) unit weights were varied over a range broad enough to cover any uncertainty and the tabulation above is based on the nost conservative set of assunptions. Out of over 250 standard penetration tests on cohesionless plant fill or natural foundation material below elevation 610, the criteria given above are not satisfied in four tests in natural meterials located below the plant fill and in 23 tests located in the plant fill. These tests involve the following boringst SW3, SW2, DC-18, AX 13 AX 4. AX 15, AX 7, AX 5, AZ 11, i DG 19, DG 13, DG 7, DC 5, D 21, GT 1, 2. Some of t.. tests on natural tutorial were conducted at depths of at less than Prior 10 f t before approximately 35 f t of fill was placed over the location. to comparison with the criteria these tests should be multiplied by a factor of about 2.3 to account for the increase in af f active overburden pressure that results from the placement and future dewatering of the fill. 1* Tor :( = 7.3, blow counts would increase by 30*:. 14 l W

M.- , 7 AL ESO 7 NCEED-T

SUBJECT:

Interagency Agreement No. NRC-03-79-167 Task No. 1 - Midland Plant j Units 1 and 2, Subtask No.1 - Letter Report Of the 23 tests. on plant fill which fail to satisfy the criteria, most are near or under structures where remedial measures alleviating necessity for support from the fill are planned. Only 4 of the tests are under the Diesel Generator Building (which will still derive its support from the f,ill) and 3 others are near it. Because these locations Were low blow counts were recorded are well separated from one another and are not one continuous } atratum but are localized pockets of loose material, no failure mechanism is present. In view of the large number of borings in the plant fill area and the conservatism adopted in analysis, these few isolated pockets are no threat to The fill area is safe against liquefaction in a' Magnitude 6.0 plant safety. earthquake or smaller Wich produces a peak ground surface acceleration of 3 or less provided the groundwater elevation in the fill is kept at or 0.19 below elevation 610. Seismic analysis of structures on plant fill material. (1) Category I Structures. From Section 3.7.2.4 of the TSAR it can of about 1350 f t/sec uns used in the be calculated that an average V, interaction analysis of the Category I original dynamic soil structure This is confirmed by one of the viewgraphs used in the 28 structures. Plant fill V, is clearly much lower than February Bechtel presentation. It is understood from the response to Q.testion 13 (10 CFR 50.54f) this value. concerning plant fill that the analysis of several Category I structures are ( underway using a lower bound average V, = 500 f t/sec for sections supported on plant fill and that floor response spectra and design forces will be taken The questions as the most severe of those from the new and old analysis. which follow are intended to make certain if this is the case and gain an understanding of the impact of this paranetric variation in foundation conditions. been (a) Discuss Wich Category I structures havegand/or will be reanalyzed for changes in seismic soil structure interaction due to the change Have any in plant fill stiffness from that envisioned in the original design. Category I structures deriving support from plant fill been excluded from reanalysis? On Wat basist (b) Tabulate for each old analysis and each reanalysis, the foundation parameters (v,,9 and P ) used and the equivalent spring and damping constants derived therefrom so the reviewer can gain an appreciation i I of the extent of parametric variation performed., (c) Is it the intent to analyze the adequacy of the structures and their contents based upon the envelope of the results of the old and new Tor each structure analyzed, please show on the same plot the old, analyses? l new, and revised enveloping floor response spectra so the effect of the l t i i 15 ( / l l ( T -- ' - -r-

g gy$-: ' i JUL icJ10 w ig ..s..my J2T' NCEED-T ?

SUBJECT:

Interagency Agreement Nc. NRC-03-79-167 Task No. 1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report ( changed backfill on interior response spectra predicted by the various models can be readily seen. (2) Category I retaining wall near the southeast corner of the Service Water Structure. This wall is experiencing some differential settlement. Boring information in Figure 24-2 (Question 24, Volume 1 Responses to NRC Requests Regarding Plant Fill) suggests the wall is founded on natural soils and backfilled with plant fill on the land side. Please furnish details clarifying the fo11 cuing: 5 (a) Is there any plant fill underneath the wall? What additional data beyond that shown in Figure 24-2 support your answer? (b) Have or should the design seismic loads (FSAR Figure 2.5-45) be changed as a result of the changed backfill conditions? (c) Have or should dynamic water loadings in the reservoir be , considered in the seismic design of this vall? Please explain the basis of your answer. In your response for the comments and questions in paragraph 4 above, if 5.you feel that sufficiently detailed information already exists on the Midland docket that may have been overlooked, please make reference to that Resolution of issues and concerns will depend on the expeditious information. ( receipt of data mentioned above. Contact Mr. Neal Gehring at FTS 226-6793 regarding questions. 70Z TEI :I;;21C2 3 C 8 Mt . la I P. McCALLISTER Chief Engineering Division l l I _ _. / i l . _M" 'M W MT MT. ae p. 4%Q7jggen,,Q] gXpggg{gp34yy;,,$gq!T T'

~ J.,..]. - ,{ L -.p !, 'j.i h <i? Y I /5 'I$ ! 31 ~fj (D/ J f f p* il, tr :i'---" = i ',!:,'j h!i?I! 4' iU'i [. b% ?. 4 l :i i' 4 1 M i C d 6 : .M - 4 m q-g f t.'s j.aT* o

%~ r.

17

t..

s t, \\ l g. n ,t..p. i b) %,\\'ie n 0. --3M e, s..il<'$: 't t s! i d '!!1! Q'"ji.I 2,Lt

  • 43I ji I

1 "\\ \\t S{S;lrpl}i i 1; / jj A S',fp

  • "51 ~ -^i'T r
.....u y

1 N.g 4-- 'F p._ g ~,. y) v 3.{ }; j,.g p v.e l h ql 1 b, d 4 .,,; c f)j$'. $dd.".'b-( Q,c-Q' {j.r.. : s a ,i -*9e\\ .V i f

  • J J

-Q-. d- ?:) g a: e ,l \\ C".:. ~~ ,e; ~ r, er 4% <.k h8e s, -{ Q l s 3 g %g ,f alj M e c,a,h1 l e g. i u T, y i / p ke g N / a s ,h- \\\\ s t

g e L-

_. g - m _. - . b> ) ' i$'// s { },, / i -- a'" N O $ de N s '1 h:,$s. y + H l f z,.g e3.. e. s ) x

)

%. /a- ' s "s a g;: .N s 'a}}