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Samuel J. Chilk Secretary FROM:
Themas R. Gibbohf/ [
Legal Assistant to Coc.issioner Bradford 3-
@0 Al D N MI L ND FROCEEDING, DOCKET !
On July 30. 1930 I had extensive discussicns with James G. Keppler Director of Region III, and other Region III persennel on general NRO enforcement issues.
'. touched briefly upon the Midland case.During the course of these general discus conversation could be considered an ex parte contac. no request that pursuant to 10 CFR 2.780 Accordingly, I proceeding and also place these documents in the PDR.the the.su=.ary of the discussion, Mr. Keppler notes that while there a'n'ith regard t some technical inaccuracies, the substance of the discussion is portrayed re correctly.
At achment:
As stated cc:
James G. Keppler s
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x..,.n/ sbr AM UNITED STATES OF AMERICA f"JCLEAR REGULATORY CO:* MISSION In :ne Matter of
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J CCNSUME:.5 POWER COMPANY l
Docket No. 50-329
("idland Nuclear Power Plant, l
50-330
.Jnits 1 and 2)
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ORDER tiODIFYING CONSTRUCTION PEDNITS I
The Consumers Power Company (the Licensee) is a holder of Construction Pemi:s Nc. CPPR-81 and No. CPPR-82 which authorize the construction of two
- ressurized water reactors in Midland, Michigan. The construction pemits ex
- ire on II On Augus: 22, 1978, the Licensee infomed the NRC Resident Inspector at the Midland site that unusual settlement of the Diesel Generator Building had been ce:e::ec. Tne Licensee reported the matter under 10 CFR 50.55(e) of the Commission's re;ulations telephonically on September 7,1978. This notification was followed by a series of interim reports dated September 29, 1978, November 7, 1978, De:e-ber 21, 1978, January 5, 1979, February 23,1979, April 3,1979, June 25,1979, August 10, 1979, September 5,1979, and November 2,1979.
Foilewin9 the September notification, inspectors from Regior$, Office of Inspection and Enforcement, conducted an investigation over the period of October, 1978 through March, 1979. This investigation found a breakdown in the quality assurance related to soil construction activities in that (1) a lack of control and i
su:ervision of plant fill activities contributed to inadequate compaction of foundation e.aterial; (2) corrective action regarding nonconfonnances related to j
21 ant fill was insufficient or inadequate as evidenced by repeated deviations from 1
spe:ification requirements; (3) certain design bases and construction specifications
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2-related to foundation-type, material properties and compaction requirements were not fcilowed; (4) there was a lack of clear direction and support between the contractor's engineering office and construction site as well as within the
. con ractor's engineering office; and (5) the FSAR contains inconsistent, incorrect, and u.supoorted statements' with respect to foundation type, soil properties and settle ent values. The detatis of these findings are described in the inspection repct s SG-323/78-12, 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, 197-respectively.
Tne items of noncompliance arising out of the NRC investigation are described in A;cendix 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 stated that "All 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 fcend unacceptable witext further Staff analysis aM questions if the Staff had k.'own that Category I s mctures had been placed in fact on random fill rather than the controlled s
coccacted cohesive fill stated to have occurred in the FSAR.
As a result of the questions raised during the NRC thvestiga, tion of the Diesel Genera or Building settlement, additional infonnation was necessary to evaluate the ir,,act of plant safety caused by soil conditions under and surrounding structures in and on plant fill and the Licensee's quaMty assurance program. On March 21,1979, the Director, Office of Nuclear Reactor Regulation, fonnally requested under 10 CFR 50.5*(f) of the Comission's regulations information concerning these matters to dete mine whether action should be taken to modify, suspend or revoke the construction permits. Additional infonnation ns requested by the Staff in letters dated l
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o Septroer 11, 1979 and November 19, 1979. The Licensee responded to these letters,,
under cath, in letters dated April 24,1979, May 31,1979, July 9,1979 September 13, 1973, and November 13, 1979. The Licensee has not yet responded to the November 19,
.1979 re:uests.
After reviewing material provided by the Licensee in response to the Staff questi r.s arising out of its investigation, 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 soil deficiencies will be acceptable. Without the res:1;ticr. of these, issues the Staff does not have reasonable assurance that the
- . w Midlard fa:ility can be constructed and operated without undue risk to the health ar.d safety of the public.
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III Under the Atcznic Energy of 1954, as amended, and the Comission's regulations, activities under construction pemits or portions thereof may be suspended should the C:rr-issier. find information which would warrant the Commission to refuse to grant a c:nstru:tien pemit on an original application.
I find that the quality assurance deft:iencies surrounding the settlement of the Diesel Generator Building and the
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soil a:tivities at the Midland site, the false statement in the FSAR, and the un-
.s resolved safety issue concerning the adequacy of the remedial action to correct the deficisn:ies in the soil work are adequate bases to refuse to grant a construction pemit and that, therefore, suspension of certain activities under Construction i
Pencits Mc. CPPR-81 and No. CPPR-82 is warranted until the safety issues are resolved.
l IV i
Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the Carrission' lations in 10 CFR Parts 2 and 50, IT IS HERE3Y ORDERED THAT m I'e s o-b
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- f %e Ortter-Cons.ruction Pemits No. CPPR-81 and No. CPPR-82 be modified as follows:
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4 (1) The Licensee shall submit an amendinent application seeking approval of the remedial actions associated with the soil activities for Category if pipes, buildings and other '
structures in and en piant fill material.
(2) Pending the issuance of the amendment of Construction Pemits No. CPPR-81 and CPPR-82 appmving the remedial action,'
Construction Permits No. CPPR-81 and CPPR-82 are mocified to prohibit, after the date of this Order (added to rake the suspension retroactive if the hearing is dragged out.s,uch that the Licensee is building at its own risk during the hear 4ng);
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(a) any placing, compaction, -or-excavating safe 4-y-Q. ;.u....,,,;. :w.
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(b) all construction work related to the Diesel Generator Building and the tank fam areas-(mgi4Wtliss-4?
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(c) physical daplementation,c' remedial a"ction for' correction
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of soil-related pmblems including but not. limited' to:
(i) de utering systens (ii) underpining of service water building (iii) caissons in valve Bit area I
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(3) Paragraph (2) above shall:not apply to any expiration, sampling, or testing of soil samples asscciated with detemining actual soil properties
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on site which has the approval of the Director of Region III, Office of Inspection and Enforcement, V
~he~ Licensee or any interested person may within 20 days of the date of this Order request an hearing with respect to all or any part of this amendment. This a end ant will become effective on the expiration of the period during which the Licensee may request a hearing, or in the event a hearing is requested, on the date soecified in an Order made followin the hearing.
VI In the eient a hearing is requested, the issues to be considered at such hearing shall be:
(1) whether the facts set forth in Part II and III of this Order are true; and (2) whether this Order should be sustained.
FOR THE NUCLEAR REGULATORY COMMISSION
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Victor Stello, Jr., Director Office of Inspection and Enforcement Attachments:
Appendix A Appendix 8 Dated at Bethesda, Maryland, this day of Decerber,1979.
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.wed-JF. 3 - T DRAFT APPENDIX A NOTICE OF VIOLATION
- .suners Power Cocyany Docket No. 50-329 Docket No. 50-330
!ni refers to the investigation conducted by the Office of Inspectics a.d I.fo:cenen at the Midland Nuclear Power Plant, U.its 1 and 2 Midland, Michigan, at your offices in Jackson, liichigan, and at Bechtel Corporation, Ann A ber, Michigan of activities authorized by NRC License Nc. CPFR-81 4 - f No. CPPP.-S O.
1::e: ::. the results of the investigation conducted during the peried Caet.-ber 11, 1975 thrcush January 25, 1979, it appears that ce: Lain of len: ar-ivities were not conducted in full compliance with NP.C require-ren s as noted below. These items are infractions.
- 2 07. 50, Appendix B, Criterion III requires, in part, that measures snall be es:ablished and executed to assure that regulatory requirensnts and the design basis as specified in the license appliestion for st ettres are correctly translated into specificatio s, drawings, prc:edures and instructions. Also, it provides that measures shall be established for the identificatien and control cf design inter-faces and for coordina-ion among participating design c sanisations.
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DRAIT Appendix A,
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 NSSS supplier AE aupplier, or CPCo) assure that designs and caterials are suitable and that they courply with design criteria and regula to.y requi rements. "
CPCo is co==itted to ANSI N45.2 (1971), Section 4.1, which states, in part, " measures shall be established and documented to assure that the applicable specified design requirements, such as a design basis, regulatory requirenents
. are correctly.rsnslated into s;ccifications, drawings, procedures, or instructions."
Centrary to the above, measures did not assure that design bases were included in drawings and specifications nor did they provide fer the identification and control of design interfaces.
As a result, inconsistencies were identified in the. license application.
a-d in other design basis docunents as set for,th below:
2 The FSAR is internally inconsistent in that FSAR Iigure 2.5-43 a.
indicates settlement of the Diesel Generator Building to be on the order of 3" while FSAR Section 3.3.5.5 (structural accept-anee critaria) indicates settlements on shallow spread footings l
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Accendix A
-founded on compacted fill to be on the order of 1/2" or less.
The Diesel Generator 3cilding is supported by a centinuous shallow spread foetin6-b.
The design settle =ent calculations for the diesel generator and berated water storage tanks were performed on the assu=ption of uniforn cat foundations while these foundations were designed and constructed as spread footing foundations.
c.
The se tl-esnt calculations for the Diesle Gen: rater Building initcated a losd intensity of 3000 PST while the ISAR. Figure 3.5-47, shows a load intensity of 4000 PSF, as actually constructed.
d.
The settlenant calculations for the Diesel Generator Enilding 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 TSAR Figure 2.5-48.
However,, TSAR, Table 2.5-16, indicates an index of compressibility of the same plant fill to be 0.003.
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PSAR, Amendment 3, indicated that if filling and backfilling e.
operations are discontinued during periods of cold weather, all
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frozen soil would be ressoved or recompacted prior to the resump-tion oi operations. Bechtel specification C-210 does not sperif-ically include instructions for remova' of frozec/ thawed co=pacted caterial upon resumption of sork after vinter periods.
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PSAR imendment 3 indicates that cohesionless soil (sand) would be co=pacted to 25* relativa density according to AS'N D-2049.
hewever, 3echtel specification C-210, Section 13.7.2 required cohesionless soil to be coupacted to not less than 80*. relative de=sity.
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10 CTK 50, Appendix B, Criterion V requires, in part, that activities affecting unality shall be prescribed and accomplished in accordance with documented instructiscs, procedures or drawings.
CP0o Topical Report CPC-1-A Policy No. 5, Section 1.0 states, in part, that, " Instructions for controlling and, perfor=ing activities affecting quality of equipment or operation during design, construe-tien and operations phase of the. nuclear power plant such as procure-cent 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 satisf actorily
'acco.plished.
- DRAIT 5-A:;aendix A 0? o is comraited to ANSI N45.2 (1971), Section 6 which states, in part, " activities affecting quality shall be prescribed by documented instru:ticas, procedures, er drawings, of a type appropriate to the circu=:7.acces and shall be acco=plished in accordance with these 4
ir.stru:tions, procedures, or drawings."
C:ntrary to the abcve, instructions provided to field construc-a.
tien for substituting lean concrete for Zone 2 material did not address the differing foundation properties which would result i: dif ferential settlement of the Diesel Generator Building.
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Also, contrary to the above, certain activities were not accon-
';.ish:d according to instructions and procedures, in that:
I. ) Re co=paction criteria used for fill material was 20,000 ft-lbs (Bechtel modified proctor test) rather than a ec=pactive energy, of 56,000 ft-lbs as =pecified in Bechtel Specification C~-210, Section 13.7. '
() 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 e
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, g Appendix A 6-with specification criteria.
This is required by Bechtel Specification C-501 as well as PSAR, Amendment 3 (Dames and Moore Report, page 16).
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U CFR 50, Appendix 3, Criteriaoc X requires, in part, that a prograc for inspect. ion of activities affecting quality shall be established and executed to verify co:formance wit.h the documented instructions, procedures and drawings for acco[cplishing the activity.
C?Ce Topical Report CpC 1-A Policy No. 10, Section 3.1, states, in pr:t, that " work activities are acconplished according to approved
- ocedures or instructions which include inspection hold points beyend which vork does no. proceed until the inspection is co..plete vritten consent for bypassing the inspection has been received c
fro = the organization authorized to perform the inspections."
CPCo is com=ited to ANSI N45.2 (1971), which states, in part, "A progran for inspection of activities affecting quality shall be established and executed by or for the ciganization perfo:uing the a:tivity to verify confor=ance to the documented instructions, procedures, and drawings for accomplishing the activity."
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Contrary to the above, Quality Control Instruction C-1.02, the program for inspection of compacted backfill issued on October 18, ICH, did c:t provide for inspection hold points to verify that soil w:r. vas satisfactorily accomplished according to docu=ented i
instructions.
4 20 CTR 50, Appendix B, criterion XVI requires, in part, that mes-sures shall be established to assure that conditions adverse to quality such as failures, deficiencies, defective material and r.s. :enfermances are promptly identified and corrected. In case of sig.ificant conditions adverse to quality, measures shall assure that corrective action is taken to preclude repetition.
t C?S Tc,-ical Report CPC-1-A Policy No.16, Section 1.0 states, in par *., " corrective actice is that action taken to correct and pre-c'ude recurrence of significant conditions adverse.to the quality of itess er operations.
Corrdctive action includes an evaluation of the cocditions that led to a nonconformance, the disposition of the r.or.confor=ance and co=pletion cf the actiods necessary to prevent or reduce the possibility of recurrence."
Centrary to the above, seasures did not assure that soils conditions of adverse quality were promptly corrected to preclude repetition.
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t DRAFT Appendix B NOTICI CT V!OLATION hr.st=ers Power Con:pa=y Docket Fo. 50-329 Docket No. 50-330
!.t: refers te '.he investigatio: conducted by the Office of I:spection a:i 1:f:rce: cst at the Midland. Nuclear Power Pla=t, U its 1 and 2, Midland, "ichiga., at your offices in Jackson, Michiga=, and at Bechtel Corporation, '
A.. Arber, ".ichigan, of activities authorized by NRC License No. CP?R-81 j
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- ..:; :his tnvestigatic: conducted on various dates betwee: Deceinber 11,
.i!* and January 25, 1979, the following apparent item of cencompliance
.az ide::ified.
Se Midla d Tical Safety Analysis Report (FSAR) contains the follovi:g:
Se:: ion 2.5.4.5.3, Till, states "All fill and backfill were placed s
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aer::di:g :: Table 2.5-9."
- '::: 2.5-9, P.inimu:s Compaction Criteria, contains the folleving:
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Corpeetio: Criteria
'iusetion Designation T ge Derree ASTM Derianation Z
Su;;cet of Clay 95%
ASTMD155{gj6T structures (modified)
a; ?:: :::e designation see Table 2.5-10.
(2 "he ceth:d was ' modified to get 20,000 foot pounds of ce=pactive e:argy per cutie foot c-soil."
Se: tics 2.5.4.10.1, Bearing Capacity, states:
" Table 2.5-14 shows the 4
cen'.act st:ess beneath footings subject to static and static plus dyna =1e ic. dings, the foundatic: elevation, and the type of supporting medic: for veri s plant structures."
Taoie 2.5-14, Summary of Contact Stresses and Ultimate 3 earing capacity for. Mat Focadations Supporting Seismie Category I and II Structures, es: sics, in part; the following:
" Unit S pporting Soils s
Diesel Generato:
Controlled compacted Buildt=g cohesiye fill."
.s Tnts ir. formation is false, in that r.aterials other than controlled compacted tonesive fill-clay were used to support the diesel generator building and 6
naterial presented conceg(ng the supporting soils influenced the staff review of the FSAR.
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Ydf$iD/1 l 90' UNITED STATES OF AMERICA
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Docket No. 50-329 (Midland huclear Power Plant,
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50-330 Units 1 and 2)
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0 DER f*00!FYING CONSTRUCTION PEP.MITS I
The Consumers Power Company (the Licensee) is a holder of Construction Fe-its.*i:. CF?R-51 and Nc. C?PR-82 which authorize the construction of two
- ressu #:st water reactors in Midland, Michigan. The construction pemits ex: ire ci fekAch.ll41/v 9N cho /,N82' undo e ad us,)y/ QeeQ/y.
On Au9ust 22,1978, the Licensee infomed the NRC Resident Inspector at the ridian: site that unusual settlement of the Diesel Generator Building had been de:e:te:. Tne Licensee recorted the matter under 10 CFR 50.55(e) of the Coninission's re;ula:':ns telephonically on September 7,1978. This notification was followed by a series cf interim reports dated September 29, 1978, November 7,1978, De:r.ter 21, 1978 January 5, 1979, Feb'ruary 23,1979, April 3,1979, June 25,1979, A;;ust 10,1975, September 5,1979, and November 2,1979.
F 11ewins the September notification, inspectors from Region $. Office of Inspecti:n and Enforcrent, conducted an investigation over the period of October, 1975 through March, 1979. This investigation found a breakdown in the quality assurance related to soil construction activities in that (p a lack of control and supervision of plant fill activities contributed to dequate compaction of foundation zaterial; % corrective action arding nonconfomances related to lant fill us insufficient or inad ate as evidenced by repeated deviations from l
spe:ification requirements; f artain design bases and construction specific,atio,ns
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2 related to foundation-type, material properties and compaction requirements were not fcilowed; @ there was a lack of clear direction and support between the contractor's engineering office and construction site as well as within the
. contractor's engineering office; and (5) the FSAR contains inconsistent, incorrect, and unsupDorted statements with respect to foundation type, soil properties and settlerent values. The details of these findings are described in the inspection 50-329/78-12, 50-330/78-12 (November 14, 1978) and 50-329/78-20, 50-330/78-20 re;crts (March 19,1979) which were sent to the Licensee on November 17, 1978 and March 22, 1979 respectively.
The items of noncompliance arising out of the NRC investigation are described in A;sendix A to this Order.
In addition as describad in Appendix B to this Order a Material False Statement was made in the FSAR in that the FSAR falsely stated that "All 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 withcut further Staff analysis and questions if the Staff had known that Category I stractures had been placed in fact on random fill rather than the controlled compacted cohesive fill stated to have' occurred in the FSAR.
As a result of the questions raised during the NRC ikvestiga, tion of the Diesel Generater Building settlement, additional information was necessary to evaluate the im:act cf plant safety caused by soil conditions under and surrounding structures in and on plant fill and the Licensee's quality assurance program. On March 21, 1979, the Director, Office of Nuclear Reactor Regulation, femally requested under 10 CFR 50.54(f) of the Comission's regulations infomation concerning these matters to l
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l deter =ine whether action should be taken to modify, suspend or revoke the construction i
wmits. Additional infomation was requested by the Staff in letters dated 1
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Septecter 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, September 13, The Licensee has not yet responded to the November 19, 1979, and Novencer 13, 1979.
.1979 recuests.
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'c Fe~ 4,x.., g,fs,.Jaterial,orovieee by the Licensee in response to the Staff questions arising out of its investigation, 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 soil deficiencies will be acceptable. k'ithout the resciation of these issues the Staff does not have reasonable assurance that the A&_d4
.1cian facility be constructed and operated without undue risk to the health and safety of the public.
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Under the Atomic Energygof 1954, as amended, and the Cornission's regulations, a:tivities under construction pemits or portions thereof may be suspended should the C:=ission find information which would warrant the Comission to refuse to grant i We ccr.straction pemit on an original application. p find that the quality assurance deficiencies surrounding the settlement of the Diesel Generator Building and the scil activities at the Midland site, the false statement in the F5AR, and the un-reselved safety issue concerning the adequacy of the remedial action to correct the deficiencies in the soil work are adequate bases to refuse to grant a construction pemit and that, therefore, suspension of certain activities under Construction retAed Pemits Nc. CPPR-81 and No. EPPR-82 is warranted until the safety issues are resolved.
A IV Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the
--d en rr te ureenv nRDERED THAT the Car.ission's regulati:.-- i-10 Cru. P. -
a Constniction Pemits No. CPPR-81 and No. CPPR-82 be modified as follows:
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(1) The Licensee shall submit an amendment application seeking approval of the re:nedial actions associated with the soil activities for Category lj pipes, buildings and other structures in and on plant fill material.
(2) Pending the issuance of the amendment of Construction Pemits No. CPPR-81 and CPPR-82 approving the remedial action.
Construction Permits No. CPPR-81 and CPPR-82 are modified to prohibig after the date of this Order *.(__'f:'
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$ Thysical implementation of E6snal es ivu.'ei wurrection of soil-related problems including but not. limited to:
(1) dewatering systems (ii) underpining of service water building (iii) caissons in valve f t area (iv) compaction and 1oading activities.f~--.J./.c:a.I",u.9t8WGu-L '
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s installation of conduits and piping
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(3) Paragraph (2) above shall not apply to any expVation, sampling, or testing of soil samples associated with detennining actual soil properties l
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..f.W.RQ3 ~t*~ T-I 5-on site which has the approval of the Director of Region III, Office of Inspection and Enforcement, V
The Licensee or any interested person may within 20 days of the date of this Order request an hearing with respect to all or any part of this amendment. This atencnent will become effective on the expiration of the period during which the Licensee may request a hearing, or in the event a hearing is requested, on the date specified in an Order made followin] the hearing.
VI In the eient a hearing is requested, the issues to be considered at such hearing shall be:
(1) whether the facts set forth in Part II 6 of this Order are true; and (2) whether this Order should be sustained.
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FOR THE NUCLEAR RE iULATORY COMMISSION' s.
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Victor Stello, Jr., Director ha-,/d 2 p r,b ' Aw,%
Office of Inspection and Enforcement W u.f-k%.leanRouhn y,
Attachments:
Appendix A Appendix 8 Dated at Bethesda, Maryland, this day of Decerter,1979.
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W Acesuone A w
myx 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 8echtel Corporation, Ann Arbor, Michigan of activities authorized by NRC License No. CPPR-81 and No. CPPR-82.
Based on the results of the investigation conducted during the period December 11, 1978 through January 25, 1979, it appears that certain of your activities were not conducted in full compliance with NRC require-ments as noted below. These items are infractions.
1.
10 CFR 50, Appendix 8, 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.
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CPCoTopicalReportCPC-1-A[licyNo.3,Section3.4 states,in part, "the assigned lead design group or organization (i.e., the NSSS supplier A&E supplier, or CPCo) assure that designs and y
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, 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."
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:
The FSAR is internally inconsistent in that FSAR Figure 2.5-48 a.
indicates settlement of the Diesel Generator Building to be on the order of 3" while FSAR Section 3.8.5.5 (structural accept-ance criteria) indicates settlements on shallow spread footings
M Appendix /k-founded on compacted fill to be on the order of 1/2" or less.
The Diesel Generator Building is supported by a continuou, shallow spread footing.
i 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.
ThesettlementcalculationsfortheDies#5kGeneratorBuilding 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, FSAR, Table 2.5-16, indicates an index of compressibility of the same plant fill to be 0.003.
i e.
PSAR, Amendment 3, indicated that if filling and backfilling j
operations are discontinued during periods of cold weather, all i
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g Appendixk '
frozen soil would be removed or recompacted prior to the resump-tion of operations. Bechtel specificatien C-210 does not specif-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 0-2049.
4 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 4
with documented instructions, procedures or drawings.
CPCo Topical Report CPC-1-A Policy No. 5, Section 1.0 states, in 9
part, that, " Instructions for' controlling and performing activities l
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.
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M Appendix /k CPCo is commited to ANSI N45.2 (1971), Section 6 which states, in part, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and sna11 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 (1) The compaction criteria used for fill material was 20,000 ft-lbs (Bechtel modified proctor test) rather than a compactive energy o'f 56,000 ft-lbs as specified in Bechtel Specification 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 3
M Appendixd
- with specification criteria. This is required by Bechtel Specification C-501 as well as PSAR, Amendment 3 (Dames and Moore Report, page 16).
3.
10 CFR 50, Appendix 8, Criteridan X requires, in part, that a program for inspection of activitias affecting quality shall be established and executed to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.
CPCo Topical Report CPC 1-A Policy No. 10, Section 3.1, states, in y
part, that " work activities are accomplished according to approved procedures or instructions which include inspection hold points beyond which work does not proceed until the inspection is complete or written consent for bypassing the inspection has been received from the organization authorized to perform the inspections."
CPCoiscommitedtoANSIN45.h(1971),whichstates,inpart,"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, procedures, and drawings for accomplishing the activity."
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Contrary to the above, Quality Control Instruction C-102
, the program for inspection of compacted backfill issued on Oct b o er 18, 1976, did not provide for inspection hold points to verify th 5
at soil work was satisfactorily accomplished according to docu mented instructions.
4 10 CFR 50, Appendix 8, Criterion XVI requires
, in part, that mea-sures shall be established to assure that conditions adverse t quality such as failures, deficiencies, defective materi l o
a and nonconformances are promptly identified and corrected In case of significant conditions adverse to quality, measures shall assure that corrective rction is taken to preclude repetiti on.
CPCo Tcpical Report CPC-1-A Policy No. 16, Section 1 0 st t 9
a es, in part, " corrective action is that action taken to correct and pre-clude recurrence of significant conditions adverse to the qualit items or operations.
y of 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 repetiti For example:
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PW Appendixd{ 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, 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-29, QF-52, QF-68, QF-147, QF-174, QF-172 and QF-199 contain numberous examples of repeated nonconformances in the same areas of plant fill construction.
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6 APPEMDN S 4Bilaild5sA.
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 December 11, 1978 and January 25, 1979, the following apparent ites of non' compliance was identified.
The Midland Final Safety Analysis Report (FSAR) contains the following:
Section 2.5.4.5.3, Fill, states: "All fill and backfill were placed according to Table 2.5-9."
Table 2.5-9, Minimus Compaction Criteria, contains the following:
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" Function Desianation mT Dearee ASTM Desianation Support of Clay
- 957, ASTMD155g6T structures (modified)
(1) For zone designat1*n.~see Table 2.5 10.
(2) The method was modified,tofsst?20,000 foot pounds of compactive energy per cubic foot of soil."
Section 2.5.4.10.1, Bearing Canseity, states: " Table 2 5 14 shows the contact stress beneath footings subject to ' static and static plus dynamic loadings, the foundation el.cvation, and the type of s qporting medium for e
various plant scructures."
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Table 2.5-14, Summary of, Contact Streshes and Ultimate Bearing Capacity for Mat Foundations Support.ing Seismic Category I and II:Jeructures, Ts
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contains, in parti the fol bwing:
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" Unit Supportin2 Soils i
Diesel Generator sA Controlled compacted Building cohesive fill."
'"I '-'er atter. is false, in that materials oth,er than centrolled coroacted
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tierial ;:reser.ted concering the supNrtinh soils influenced the staff rev'iew s
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