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DEPARTMENT OF THE ARMY
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2 7 MAR 198i NCEED-T
SUBJECT:
Interagency Agreement No. NRC-03-79-167, Review of the Applicant's Response to Nuclear Regulatory Commission Staff Interrogatories Regarding Midland Nuclear Plant.
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4 U. S. Nuclear Regulatory Commission ATTN:
Mr. George Lear, Chief Hydrologic & Geotechnical Engrs. Branch Division of Engineering Mail Stop, P-214 Washington, DC 20555 4
1.
As requested by the staff, we have reviewed the applicant's response to
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the NRC Interrogatories 1, 2 and 3, and the following are our review comments.
a.
Since the applicant has not conducted consolidation tests on samples obtained from the surcharged area of the plant fill (Diesel Generator Building), there are no results available for review for the Interrogatories 1 and 2.
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The applicant has indicated on page 3 of its response that the live j
load expected to be transferred to the foundation soil has been conservatively f
estimated to be 25% of the full design live load. In our opinion, the I
reduction of the design live load to 25% of its actual value for computation of settlement is not justified. We understand that dead loads of the 1
equipment, piping etc. have been considered as part of the live load. These loads constitute a major part of the live load and are permanent in nature, therefore, no reduction factor should be applied'for this part of the live u
load. A reduction factor may be applicable to the portion of the live loads such as moving loads (cranes, hoists, etc.) and their impacts. The applicant should separate the live loads in two groups (1) live loadswhich are permanent in nature (2) moving loadu or loads that change positions more often and then
'l apply a reduction factor to the moving load portion only. The portion of the live load in (1) should be considered in full in computation of settlements.
Further, a reduction to 25% appears to be too high. The applicant should pro, vide justification for such high percentage reduction.
2.
In the last sentence on page 3 of the response, the applicant has stated that the live load portion (.8kps in stages V and VI) consists of the approximate full live load of the roof, intermediate floor and grade slab.
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[l 2 7 MAR 1981 L.
NCEED-T C
SUBJECT:
Interagency Agreement No. NRC-03-79-167, Review of the Applicant's I
Response to Nuclear Regulatory Comission Staff Interrogatories 4
Regarding Midland Nuclear Plant.
It is our understanding the 0.8 kps has been obtained by deducting Stage V load on 16 January 1980 (2.2 kips) from Stage V load on 31 December 1981 (3.0 l
kips) of Table 4-1A.
However, from the heading of Table 4-1A, it is clear that this table pertains to building load only, therefore, loads shown at various stages must be the dead load of the building only. The applicant j
should clarify this discrepancy.
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fl P. McCALLISTER lf Chief, Engineering Division
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2 MEMDRANDUM FOR: Robert L. Tedesco, Assistant Director for Licensing
. Division of Licensing 1
I THRU:
Elinor G. Adensas, Chi Licensing Branch No. 4 Division of Licensing FROM:
Darl Hood, Project Manager J;
Licensing Branch No. 4 Division of Licensing
SUBJECT:
REVISED HEARING SCHEDULES FOR MIDLAND i
Backgrcund On October 16, 1981, and following internal discussions with the Division of Engi-neering and (by telephone) me, OELD participated in a conference call with Consumer's legal representatives and the Licensing Board to discuss revise'd sched-ules for the Midland soils hearing. The instant hearing is directed to the CP level of information needed to deteristne the adequacy of proposed modifications to structures located on inadequately compacted fill. The revised schedule is L
requested by Consumers in order to better accolunodate their finnediate construction schedules (i.e., to address first certain limited remedial activities said to be
'A critical to their construction needs) for which it is perceived that NRC staff l
concurrence is possible prior to the hearing start.
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Problem Alert 1he applicant considers the Auxiliary Building to be schedule critical. Because the remedial actions for the Service Water Structure and Auxiliary Building are quite similar (especially for initial preparations), the applicant proposes that the two reviews be combined where possible. The NRC staff agreed to review certain recent submittals made by Consumers and to indicate on October 30, 1981, just what construction activities are likely candidates. Two candidates identified during the discussion are (1) installation of the vertical access shafts for the Auxiliary Building and the Service Water Structure and (2) installation ofi freeze wall
'i within the deeper soil layers around the Auxiliary Building to serve as an under-ground dam during excavation beneath the structures.
It was agreed that the hearing for construction activities for which agreement could be reached on the Auxiliary Building and Service Water Structure would be held December 1 - 4, 1981. Hearing testimony would be filed November 16, 1981.
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e It was.also agreed that the next hearing session after that would be December l'4 18, 1981, and would discuss (1) seismic models for the Auxiliary Building and Ser-
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vice Water Stnicture, (2) the Borated Water Storage Tanks, and (3) possibly the i
y underground piping. Testimony is to be filed November 30, 1981. The hearing on the
.i Diesel Generator Building is deferred to January 5 - 13, 1982, with testimony due December 21, 1981.
No further hearing sessions have been established at this time, but several sub,jects remain. These include prenanent,dewaterbg, structural analysis and crack modeling for all structures on fill. Considering the present technical status, it is quite likely that significant carryover from the December and January hearing sessions will occur.
Under the initial schedule, the hearing session was to be completed on December 18, i
1981. Now, completion of the hearing sessions before the end of February 1982 appear unlikely. The OL SER, scheduled for issuance May 6,1982, many be paced by 1ssuance of the Board's decision.
i Problem The NRC staff has not opposed the applicant's request to rearran'ge the hearing topics 1
and schedules to accommodate the immediate construction impact concerns. The problem is that these immediate construction activities are merely preparatory to a larger construction step, namely actual construction of underpinning, At present, it would appear to be highly unlikely, both fr6m a technical review status and from a legal status, that underpinning authorization by the staff caa be granted by January 1, 1982, as needed by the applicant. The legal question involves whether staff concur-rence can be granted while the matter is still before the Board, and whether under-pinning constitutes a "significant hazards" consideration. The applicant's position is that 50.55(e) provides for cor.tinued construction and that structural foundations are not covered by principal architectural engineering criteria required by the CP.
If this larger step can not be taken in early 1982 as the applicant wishes, then our present redirection constitutes a " hurry up and wait" situation achieved at the expense of a longer hearing schedule and increased potential of impact to the OL review and SER issuance. The applicant intends to escalate its position that under-pinning construction can and must begin January 1,1932, to staff management.
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.T A realistit: assessment of NRC staff limitations and, capabilities to achieve and authori7e underpinning of structures on January 1,1982, is needed. The results of the assessment should be used to determine what course of action would lead to minimum delay in issuance of the OL SER.
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5l x4. No, M Darl Hood, Proje er
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Licensing Branch No. 4 Division of Licensing cc:
H. Denton D. Eisenhut R. Vollmer J. Knight W. Olmstead W. Paton G. Lear F. Schauer R. Bosnak J. Kane R. Gonzales F. Rinaldi A. Cappucci J. Rajan R. Landsman J. Kimball J. G11 ray
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James w cook MGff,f Vice Pressdent - Projects, Engsmeersng 1
~~t and Construction o.nw.s om to4s w = rernais no.e. J = sea, us 4emot. <stri 7sabo4sa i
October 19, 1981 l
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Mr Harold R Denton, Director l
Office of Nuclear Reactor Regulation US Nuclear Regulatory Cosmaission Washington, DC 20555
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MIDLAND PROJECT DOCIET NOS 50-329, 50-330 NRC AUDIT OF SEISMIC AND STRUCTURAL DESIGN CALCULATIONS FILE 0460.2, B3.0 SERIAL 14315
REFERENCES:
(1) ASCHWENCER LETTER TO JWCOOK/LHCURTIS, DATED JULY 7, 1980 (2) JWC00K LETTER TO RLTEDESCO, SERIAL 10109, DATED NOVEMBER 26, 1980 (3) DSHOOD NOTICE OF STRUCTURAL DESIGN AUDIT.FOR MIDLAND, DATED MARCH 16,1981 ENCLOSURES:
(1) TEN-VOLUME SET "NRC STRUCTURAL TECHNICAL AUDIT"
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(2) ERRATA SHEETS FOR VOLUMES 2 AND 3 0F THE NRC AUDIT i
TEAM'S TEN-VOLUME SETS (3) FINAL REPORT ON NRC STRUCTURAL AUDIT OPEN ITEMS (4) DRAWINGS FOR THE DIESEL GENERATOR BUILDING i
In the NRC's July 7, 1980 correspondence, Reference 1, we were advised of the Staff's intention to perform a seismic and structural design analysis audit of major safety-related structures as part of their review of the Midland application for operating licenses. The addit was subsequently held during the week of April 20-24, 1981 in Bechtel's Ann Arbor offices. In preparation j
for this audit, comprehensive written responses were prepared addressing the Staff's guideline questions forwarded by Reference 1.
These guideline i
l questions and our written responses were arranged into several bound ten-l volume sets which were used by the NI(C's audit team during the audit. At the i
conclusion of the audit five (5) ten-volume sets of the Midland structural audit questions and responses were presented to members of the NRC's review team to take with them.
As requested we are forwarding five (5) additional ten-volume sets to serve as the NRC's record copies. These complete sets (Enclosure 1) already contain the errata sheets of Enclosure 2 and the additional revisions contained in.
For those NRC audit team members who were provided with bound volume sets, we are forwarding copies of the errata sheets (Enclosure 2) which should be inserted into Volumes 2 and 3 of those 10-volume sets already in their possession. The errata sheets of Enclorure 2 have been reproduced on blue pages, except for the FSAR figures, to identify them as revisions.
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- 1'l We are also forwarding five copies of Enclosure 3 which is the final report en the structural audit open items. This enclosure contains the listing of open items from the audit and identifies the actions being taken on these NRC g
Separate copies of Enclosure 3 are being forwarded directly to NRC concerns.
,3 audit team members because additional revisions to the bound ten-volume sets are contained in this final report.
I During a discussion with the NRC Staff and its consultant, the Naval Surface I
Weapons Center, held on May 28, 1981, the NRC requested drawings of the diesel generator building to allow preparation of an independent mathematical model of the structure for dynamic analysis. By copy of this correspondence to the Naval Surface Weapons Center, we are forwarding two additional sets of the
,j drawings and information identified in Enclosure 4. One set of Enclosure 4 drawings were previously forwarded directly to the Naval Surface Weapons
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ll Center on July 17, 1981. Included for use are the Blueprints C-1001 through
- 1 C-1009 and A-350'through A-352 which detail the structural features of the
<liesel generator building. /.lso included are two sketches showing the j
mathematical model and locations and weights of major pieces of equipment in this structure.
We believe this completes the outstanding items from the NRC structural design audit. The ten-volume audit sets of Enclosure 1 are now in their final form and no further revisions will be made to this document. The resolution of any remaining more long-term issues which may relate to the NRC structural audit will be documented by FSAR revisions or in separate correspondence to the NRC.
JWC/RLT/dsb CC RJCook, Midland Resident Inspector, w/o
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GHarstead, Harstead Engg Assoc, w/2, 3 -
i PCHuang, Naval Surface Weapons Center, w/2, 3,4 FRinaldi, NRC/SEB, w/2,3
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NUCLEAR REGULATORY COPMISSION i
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-329-0M 50-330-0M
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CONSUMERS POWER COMPANY 50-329-OL (Midland Plant, Units 1 and 2)
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50-330-OL
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NRC STAFF'S ANSWERS TO INTERROGATORIES FILED
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Interrogatory 1
!;4;j Define " acceptance criteria," as that tenn is used at page 3 of the it l4 Order.
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3 Answer i
i Acceptance criteria are the standards on which a judgement or decision is based. As used in the December 6,1979 Order on Modification, the f
d standards to be used by the licensee to make its judgment or decision that Il proposed remedial measures are acceptable was sought by the NRC for its review. This infonnation was required to be submitted by the licensee in order for the NRC to determine whether there was reasonable assurance that the facility, as modified by the proposed remedial measures, can be con-structed.,and operated without undue risk to the health and safety of the public.
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The NRC practice in perfonning radiological safety reviews is such that the tenn " acceptance criteria" has a wide meaning and it is this broader meaning that applies as the tenn is used within the Order. The NRC practice is to use a document entitled " Standard Review Plan for the Review'of Safety I
il Analysis Reports for Nuclear Power Plants," NUREG-75/087, for the radiological l
l safety review of applications for licenses of nuclear power plants such as the Midland Plant.
Each section of the Standard Review Plan (SRP) is organi-I zed into four subsections, and one of these subsections is entitled " Accept-ance Criteria". This subsection contains a statement of the purpose of the review and the technical basis for determining the acceptability of the j
design or the programs within the scope of the area of review of the SRP
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section. The technical bases consists of specific criteria such as NRC l
Regulatory Guides, General Design Criteria Codes and Standards, Branch Technical Positions, and other criteria. This subsection is further dis-cussed in the first section of the Standard Review Plan, which is entitled
" Introduction".
t To illustrate the tenn " acceptance criteria," refer to SRP Section 2.5.4II, page 2.5.4-3 and Section 2.5.5II, page 2.5.5-1.
SRP Section 2.5.4 is entitled
" Stability of Subsurface Materials and Foundations," and SRP Section 2.5.5 I
is entitled " Stability of Slopes." From these examples it is seen that 4
" acceptance criteria" for the pertinent geotechnical review areas would include, for each specific and important engineering feature, a thorough L
evaluation of the particular engineering aspect based on analyses of basic h
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data that support all conclusions. These analyses and basic support data l
are required to allow the Staff to conduct independent analyses and reach 0
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, ind3 pendent conclusions on whether reasonable assurance of plant safety exists.
Interrogatory 2 State which "of the Staff's requests were directed [as of or before December 6,1979] to the determination and justification of acceptance criteria to be applied to various remedial measures taken" (Order at page 3) and which portion of each request was so directed.
l Answer Attached Table 2-1 lists Staff's requests that were directed to the
,j determination and justification of acceptance criteria to be applied to various remedial measures taken and proposed by Consumers. As of Decem-1
.1 ber 6,1979, the only remedial action that had been taken was the placement of the sand surcharge inside and around the Diesel Generator Building, which j
had reached the maximum height of 20 feet above final plant grade on April 7, N and which had been removed by August 31,1979.E The requests in
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1979 Table 2-1 relevant to the remedial action for the Diesel Generator were Requests number 4, 5, 8,12,13,14,18,19, 20, 21(c), 25, 26, 27, 28, 30, i
and 35.
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S. Howell latter of April 30 1979 to J. Keppler, forwarding MCAR 24 Interim Report 5.
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y S. Howell letter of November 2,1979 to J. Keppler, forwarding MCAR 24 Interim Report 8.
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, 4 In addition to the requests listed in Table 2-1, the Staff had pre-
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viously submitted other requests to Consumers directed to the determina-tion and justification of acceptance criteria to be applied to various 1
remedial measures taken and proposed by Consumers. These requests are identified in Appendix A hereto. Seismic issues to be resolved are dis-cussed in the answer to Interrogatory 11.
TABLE 2-1 4
Staff's 50.54(f)
Signatory /Date of Applicable Portion Request No.
Request Letter of Request 4
H. Denton, 3/21/79 All
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5 All I
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All 8
First and third sentences 9
All 10 All 11 All 12 All 13 All 14 All 15 All 16 All 17 Third and fourth sentences 18 All 19 Second and third sentences i
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Signatory /Date of Applicable PortionY
' Request No.
Request Letter of Request l
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21 Subparagraph (c) j 24 L.S. Rubenstein, 11/19/79 All 25 All 1
26 All 1
27 All l
28 All i
29 All 30 All i
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31 All 34 All 35 All i
NOTES:
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Portion of Staff's request directed to the detemination and justi-
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fication of acceptance criteria to be applied to various remedial measures taken or proposed.
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APPENDIX A l
NRC REQUESTS PRIOR TO DECEMBER 6. 1979 OTHER THAN 50.54(f) REQUESTS
.2 Signatory /
Applicable PortionM Staff Request Date of Request Letter of Request 130.21 S. Varga, 12/11/78 All 362.12 First sentence 362.13 All but last sentence
, m 6-Signatory /
Applicable PortionM Staff Request Date of Request letter of Request
- (if 40.106 S. Varga,1/18/79 All 130.23 All, with respect
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to Category I structures other than Containment.
Q 130.24 All, with respect to Category I structures other than Containment.
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All 362.14 362.15 All
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I 362.16 All 362.17 All i!
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If Portion of Staff's request directed to the detemination and justifi-ll cation of acceptance criteria to be applied to various remedial measures q
taken and proposed.
l Interrogatory 3 State and explain the reasons why "such [ acceptance 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 l-action." (Order at page 3.)
l Answer l
Technical adequacy and proper implementation are two of the principal ingredients necessary to the Staff conclusion regarding reasonable assurance as to whether the facility as proposed to be modified can be constructed and e---
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!t operated without undue risk to the health and safety of the public. The licensee's criteria, as defined in response to Interrogatory 1, and the f
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. specific details of the remedial action constitute the basis of review from
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which such conclusions by the Staff are derived.
Interrogatory 4
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State and explain the basis for the statement, at page 3 of the Order, s
that "the infonnation provided by the licensee fails to provide such criteria."
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(Acceptancecriteria.)
(Order at page 3.)
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l Answer 1
j The reply to Interrogatory ti(d) identifies which of the licensee's 1
.j responses the Staff found to be inadequate as of December 6,1979, and the-l response to Interrogatory 6(f) explains why. The responses were inadequate, in part, because they did not provide the acceptance criteria, as defined in the response to Interrogatory 1, which the Staff requires for its radiological
[.l safety review. Consider, for example, 50.54(f) Request 4 which on March 21, J
1979 in part asked (1) what criteria the licensee would use to judge the q
acceptability of fill, structures, and utilities upon conclusion of the y
preload program. -(2) what extent of residual settlement would be pennitted, and (3) the basis for the limit. The licensee's tnost recent reply prior r
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to December 6,1979 (Revision 3 to Amendment 72 dated September 13,1979)
I stated that the criteria and the extent to which residual settlements would m
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a t be pemitted would be provided by December 1979.k Therefore, the licensee's reply did not include acceptance criteria and the Staff considered the
' response to be inadequate and the matter remains unresolved.
For further examples, refer to the response to Interrogatory 6(f).
Interrogatory 5 State with particularity each iten of infonnation the Staff requested up and until December 6,1979 with regard to acceptance criteria.
Answer The items of infonnation the Staff requested up and until December 6, 1979 with regard to acceptance criteria are given in the reply to Interroga-tory 2. -
Interrogatory 6 With regard to each iten of infomation identified in response to Interrogatory 5, state: (a) the identity of the request; (b) whether Con-sumers responded to that request; (c) the identity of the communication that the Staff considered Consumers response to the request; (d) whether the Staff considered the response adequate; (e) the identity of the communica-tion by which the Staff communicated its position as to the adequacy or inadequacy of the response; (f) the basis for the Staff's position regarding 3]
The licensee's response was ultimately submitted February 28, 1980 by Amendment 74; or about 10 months after the full surcharge for the Diesel Generator Building had been placed and 6 months after the sur-charge had been completely removed.
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9-Jadequacy or inadequacy of Consumers response; and (g) the Staff personnel responsible for determining whether Consumers' response was adequate or inadequate.
Answer 4
With regard to each item of infonnation identitifed in response to Interrogatory 5 (which in turn refers to the answer to Interrogatory 2),
Table 6-1 responds to parts (a), (b), (c), (d), (e) and (g) of Interroga-tory 6.
Answers to parts (e) and (f) of Interrogatory 6 follow.
For those requests shown in Table 6-1 to be issued before December 6,1979, but for which replies were initially made after December 6,1979, refer to
.f the answer to Interrogatory 8.
Similar infonnation for requests identified in Appendix A is provided by Appendix B.
Regarding part (e) of Interrogatory 6, the means by which the Staff comunicated its position as to the inadequacy of the licensee's response was primarily by the issuance of additional questions on the same subject.
These followup requests are listed in Table 6-1.
For example,' 50.54(f)
Request 35 specifically indicated the response to previous Request 5 was unacceptable. It is not Staff practice to indicate acceptable responses to licensees, except by seperate request on a case-by-case basis. Such indi-
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evaluation report for those responses which are of significance to that report.
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The basis for the Staff position of inadequacy shown by part (f) of
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Interrogatory 6 is that the licensee's response failed to meet the Staff's acceptance criteria as defined in response to Interrogatory 1.
Specific reasons for failing are given below, and typically include not being fully
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responsive to the Staff's requests or insufficient submittal of basic data
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to support the conclusions or positions submitted by the licensee.
Consumer's responses to 50.54(f) Requests 4, 5, 6,12 and 21(c) were g
inadequate because of missing infomation or data or the responses raised additional questions. The portions of these requests which were inadequate are identified by the followup requests listed under Column 6(e) of Table 6-1.
The response to 50.54(f) Request 13 is inadequate because Consumers has not completed its analysis of the. Category I structures affected by the settlement factoring in the effects of settlement (ie., cracks, modeling changes, and material properties changes). Consumers acknowledges the
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continuing nature of their studies in their answer to Request 13.
The response to 50.54(f) Request 14 is inadequate because Consumers has not completed its analysis of the Category I structures affected by the settlement, factoring in the effects of the settlement (ie. cracks, modeling
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changes, material properties changes). Consumers has provided some infor-
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mation on the cracks present in most Category I structures, but has not detemined the related load and the related changes to analytical models and material properties.
In addition Consumers has not detemined if the cracks will continue to propagate.
The response to 50.54(f) Request 15 is inadequate because Consumers has not acknowledged the fact that differential settlement as used in the load 6
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combinations is not a self-limiting effect.
In addition we have not accepted the proposed fixes.
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The response to 50.54(f) Request 16, although responsive, is of a nature that additional tvork by Consumers is required for an acceptable reply.\\.
? 50.54(f) Request 17 asked how code-allowable conditions of underground Catedry I piping will be assu'ed throughout plant life. The reply contained
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no commitment to use the 3,0Sc limit of part NC-3652.3 of Section III of the
, ASME Code, Division 1.
Mcwwei, the response, in Table 17-2, did indicate that the Code caTculations' were used..The response provided a comparison of the ASME Cooe limit to the calculated pipe stresses resulting from settlement.
Fiam the[ response, it was not clear whether this response to the Code was l
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for illust.ative purposes only, or whether it was intended to represent Consumer's criteria. The' reply provided no acceptance criteria for inclu-(
g sion of future dettle'nept rf buried piping over the life of the plant.
Also, no critehta was provided for cases where the allowable stresses were s
exceeded.
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50.54(f) Request 18 ayked for an identification and description of f
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ievaluations of seismic Category I piping to assure that it could withstand increased differential settlement between buildings, within the same build-frg, or within the piping systems itself without exceeding code-allowable
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s stress criteria'. Request 18 also asked for the licensee's plans to assure compliance with code allowable stress criteria througbeut the life of the plant. The response fc7 seisnsic Category I piping between structures makes
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which codes or as to what specific acceptance criteria the piping is to q
j-meet. Therefore, more specific criteria as to the stress limits to be used q
are required.
4 50.54(f) Request 20 asked for acceptance criteria required to define f
l acceptable loads or components and supports produced by pipe deformations e
B due to settlement. The reply defined no acceptance criteria, but only stated that the loads on components were within the allowables. The reply provides no acceptance criteria as to when flanged joints will be disassem-bled and the methods for detemining nozzle loads. Acceptance criteria for i
the allowable differential settlement for the 2-inch and smaller diesel
'l generator fuel oil lines was not addressed.
As noted in Appendix B, the response to Staff Request 40.106 was con-sidered to be inadequate. The response was in conflict with the response to Request 20. Specifically, the response to Request 20 indicated that a stress analysis for the diesel generator fuel oil lines was unnecessary
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because of the inherent flexibility of small piping (11/2" to 2" diameter);
whereas the response to Request 40.106 indicates an extensive program for monitoring and analysis of this same piping would be perfomed. Consumers position needs to be clarified.
For reasons indicated by followup Requests 25 and 26, the response to n
Request 130.21 as noted in Appendix B was inadequate. Consumers did not complete the answer to this question to our satisfaction. Consumer's r
response refered to other 10 CFR 50.54 requests and responses. The evalua-tions of Category I structures have not been perfonned to our satisfaction.
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The applicant has nct justified in full the proposed fixes and has not provided a detailed evaluation of its analysis and design.
The response to Request 130.23 as noted in Appendix B was inadequate i
because the current criteria requires the use of ACI 349 as supplemented by Regulatory Guide'1.142./ In addition the effects of the settlement (i.e.,
cracks, change in modeling, change in material properties) need to be fac-tored in the analysis and design of these Category I structures. Further-
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more, the answer addressed only the internal structures to the containment building and-the auxiliary building but deferred any consideration for other Category I structures.
The response to Request 130.24 as noted in Appendix B was inadequate
]l because Consumers did not complete its evaluation of all Category I struc-
~l tures for the effect of the use of Regulatory Guides 1.60 and 1.61 in place of its proposed seismic response spectra and related damping values. The effect of settlement should be factored into Consumer's reevaluation.
f Certain Consumer's responses were indicated to be inadequate. Consumer's responses to Requests 362.13. 362.14 and 362.16 were inadequate because the Staff concern raised in these rd 3 questions were not to be fully resolved atil Consumers complete < Wtbul field and laboratory work. Ultimately these issues have been punued by t,he Staff in subsequent 50.54(f) requests
.as identified in Appendix B.
The portions of the resp. se to Request 362.17 which deal with predicted settlement are similar to the above in that field ek had to be completed before the issue could be resolved. The portion of the response pertaining to induced vertical stresses versus depth was unresponsive in providing needed specific data and results.
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TABLE 6-1 Identity of Whether
Response
Staff's Follow-up Responsible 50.54 (f).
Consumer Identification Consideration Requests' Staff Request Responded as of 12/6/79 of Resixmse Personnel as of Adequacy 12/6/79 as of 12/6/79 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 4 Yes Rev. 3, 9/13/79, Inadequate 2 7, <4 'O L. Heller &
Responses to NRC D. Gillen Requests Regarding Plant Fill 5
Yes Rev. O, 4/24/79, Inadequate 35, 37 L. Heller &
Responses to NRC D. Gillen i
Requests Regarding Plant Fill 6
Yes Rev. 3, 9/13/79, Inadequate 31, 33, 43 L. Heller &
Z Responses to NRC D. Gillen Requests Regarding Plant. Fill 2
[
i 8
Yes Rev. O, 4/24/79 Adequate H. Balujian Responses to NRC L. Heller Requests Regarding D. Gillen Plant Fill 9
Yes Rev. O, 4/24/79,
Response
Refer to L. Heller &
Responses to NRC referred to
%Kluest ]2 D. Gillen Requests Regarding Question 12 Plant Fill i
10 Yes Rev. O, 4/24/79
Response
Refer to L. Heller &
Responses to NRC referred to Request 12 D. Gillen Requests Regarding Question 12 Plant Fill 11 Yes Rev. O, 4/24/79 Adequate L. Heller &
Responses to NRC D. Gillen Requests Regarding Plant Fill t
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' TABLE 6-1,
Identity of-Whether
Response
Staff's Follow-up Responsible
')
50.54 (f)
Consumer Identification Consideration Requests-Staff-T Request Responded as of 12/6/79 of Response Personnel as of Adequacy as of 12/6/79 12/6/79 G,
6'(a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 12 Yes Rev. 3, 9/13/79, Inadequate 38,39,41,42,43, L. Heller &
Responses to NRC 44,45,46,47,48 D. Gillen Requests Regarding Plant Fill 13 Yes Rev. 1, 5/31/79
-Inadequate 25,48-R. Lipinski Responses to NRC F. Rinaldi Requests Regarding F. Schauer Plant Fill f
k a
14 Yes Rev. 3, 9/13/79 Inadequate 25, 28, 29 R. Lipinski
[
i 7
Responses to NRC F. Rinaldi n
Requests Regarding F. Schauer Plant Fill 15 Yes Rev. 3, 9/13/79 Inadequate 25, 26 R. Lipinski q
Responses to NRC F. Rinaldi i
Requests Regarding F. Schauer i
Plant Fill 16 Yes Rev. 0, 4/24/79 Responsive 34 L. Heller &
t Responses to NRC but additional D. Gillen Requests Regarding work by Consumers Plant Fill required to' resolve 17 Yes Rev. 2, 7/9/79, Inadequate
'45 3/
R. Stephens Responses to NRC A. Cappucci Requests Regarding Plant Fill 18 Yes Rev.
O, 4/24/79, Inadequate 3/
R. Stephens
~
Responses to NRC A. Cappucci Requests Regarding Plant Fill
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TABLE 6-1 [
(
Identity of Whether
Response
Staff's Follow-up Responsible 50.54 (f)
Consumer Identification Consideration Requests Staff Request Responded as of 12/6/79 of Response Personnel l
y as of Adequacy as of 12/6/79 12/6/19 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 19 Yes Rev.
O, 4/24/79, Not determined if R. Stephens t
Responses to NRC (and presently A. Cappucci Requests Regarding under review)
Plant Fill 20 Yes Rev. 2, 7/9/79, Inadequate 1/
R.
Stephens t
Responses to NRC (and presently A. Cappucci Requests Regarding underreview)
Plant Fill a
21(c)
Yes Rev. O, 4/24/79, Responsive but 35,37,40 L. Heller 7
Responses to NRC Inadequate J. Kane Requests Regarding D. Gillen Plant Fill 24 through 31 No (after 12/6/79) 34,35 No (after 12/6/79)
Notes:
If See Enclosure 3 to " Summary of January 16, 1980 Meeting on Supplemental Requests Regarding Plant Fill," dated February 4, 1980.
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L APPENDIX B, Identity of Whether Communication Staff's Fol l o w-u p -..
Responsible.
Request
. Consumer Identification Consideration' Request Staff Responded as of 12/6/79 of Response Personnel as of Adequacy
{
12/6/79 as of 12/6/79 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 362.12 Yes FSAR Rev. 24, 9/79, Adequate L. Heller Responses to NRC D. Gillen Questions t
362.13 Yes FSAR Rev. 20, 4/79, Inadequate 4.5,7,9,12,13,14 L. Heller Responses to-NRC D. Gillen Questions 362.14 Postponed FSAR Rev. 24, 9/79, Inadequate.
9.10,12,15 L. Heller Responses to NRC
Response
D. Gillen 7
Questions postponed to future date.
362.15 Yes FSAR Rev.24, 9/79, Adequate L. Heller Responses to NRC D. Gillen Questions 362.16 Yes FSAR
. Responsive but 4,12 L. Heller Responses to NRC submittal of D. Gillen Questions needed revised settlement analysis postponed to future 362.17 Yes FSAR Rev. 24. 9/79, Inadequate 4,8,14 L. Heller D. Gillen 130.21 Yes FSAR Rev. 24, 9/79, Inadequate 25,26 R. Lipinski j
Responses to NRC F. Rinaldi Questions F. Schauer 7
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APPENDIX B
~
_ Responsible-Identity of Whether Communication Staff's
. Fol l ow-u p'.
Request Consumer Identification Consideration
. Request-Staff Responded as of 12/6/79 of Response Personnel F
j as of Adequacy 12/6/79 as of 12/6/79 f
+
+
f 6 (a) 6 (b) 6 (c) 6 (d)
'6-(e) 6 (g)
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L
(?) 130.23 Yes FSAR Rev. 24, 9/79, Inadequate 25,26 R. Lipinski ?
l Responses.to-NRC F. Rinaldi Questions F..Schauer i.
(?) 130.24 Yes FSAR Rev. 24, 9/79, Inadequate 25,26 R. Lipinski ?
Responses to NRC F. Rinaldi Questions F. Schauer l
40.106 Yes FSAR Rev. 24, 9/79 Inadequate 20 H. Balujian Responses to NRC (clarification R. Stephens
.y Questions required)
A. Cappucci ih
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1 Interrogatory 7 p
State with particularity each iten of information the Staff reque.ted
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after December 6,1979 with regard to _ acceptance criteria.
6 Answer o
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TABLE 7-1 Signatory /Date of Request Applicable Portion Staff's Request No.
Communication of Request g
36, 37, 38 A. Schwencer, All June 30, 1980 39 through 48 A. Schwencer, All August 4, 1980 49 through 53 R. Tedesco, All August 27, 1980
. to Darl S. Hood, Items 1-8
" Summary of January 16, February 4, 1980 1980 Meeting on Supplemental Requests Regarding Plant Fill",
2/4/80 NRC Sta.ff Interroga-W. D. Paton Interrogatories tories to Consumers November 26, 1980 1-9 Fwer Company, November 26, 1980 NRC Staff Interroga-W. D. Paton Interrogatories tories to Censumers January 2,1981 1,10,11,15 and 16 Power Company, January 2, 1981 t
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L Interrogatory 8 Witn regard to each item of information identified in response to Interrogatory 7 state: (a) the identity of the request; (b) whether Con-sumers responded to that request; (c) the identity of the communication that the Staff considered Consumers response to the request; (d) whether the Staff considered the response adequate; (e) the identity of the communica-tion by which the Staff communicated its position as to the adequacy or inadequacy of the response; (f) the basis for the Staff's position regarding adequacy or inadequacy of Consumers response; and (g) the Staff personnel responsible for detennining whether Consumers' response was adequate or inadequate.
Answer This answer is provided in Table 8-1.
Additionally, Table 8-1 includes items of infonnation the Staff requested before December 6,1979 with regard to acceptance criteria, but for which the initial reply by Consumers had not been submitted as of December 6,1979.
Regarding part (f) of Interrogatory 8, it is not Staff practice to
[
indicate acceptable responses to licensees, except by separate request i
considered by the Staff on a case-by-case basis. Such indication of accept-ance is the function of the Staff's safety evaluation report for those responses which are of significance to that report. The means most fre-quently used by the Staff to communicate its position regarding inadequate responses during the course of the safety review is by issuance of addi-tional questions on the same subject. Such followup requests are listed in Table 8-1.
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Parts (d) and (g).of 50.54(f) Request 24 involved review by both geo-technical and hydrologic engineering disciplines. The parts of Response 24 g
3 indicated to be inadequate were the subject of followup requests or an NRC interrogatory to Consumers identified in column 8(e) of Table 8-1.
These followup matters provide the basis for the conclusion regarding inadequacy
]
l by the Staff.
The response to 50.54(f) Request 25 is responsive to our request but is
~
not complete. Consumers does not address the effects of the cracks on the load combinations, the rationale to the proposed fixes for Category I struc-tures, the modeling to be used in the analyses, the justification for material properties used in the analyses and design and a comparison of the results with suitable acceptance criteria.
The response to 50.54(f) Response 26 is inadequate because Consumers has not considered the effects of settlement in its analysis of the Category I structures.
Consumers states that the effects of differential settlement on Category I structures utilizing corrective measures are negligible while they propose further investigations for the Diesel Generator Building. We feel that the effects of differential settlement (i.e., cracks, modeling changes, material properties changes) needs to be considered for all Cate-gory I structures founded fully or partially on the fill material.
The response to 50.54(f) Response 28 is inadequate because Consumers does not address the concerns identified in our followup requests 25,28 and
- 29. Consumers provides additional infomation on crack mapping but does not address analytical considerations, s
f
- r s u+== a The response to 50.54(f) Response 29 is inadequate because the effects of the cracks have not been satisfactorily included in the analysis. How-ever, Consumers attempted to identify the cracks in these inaccessible areas. The Staff feels that the effect of the structural cracks in the 1
Category I structures should be considered in the re-analysis of these structures.
The response to 50.54(f) Response 30 will ba adequate if Consumers classifies the duct banks as Category I structures with no requirement for maintaining a pressure boundary for the cables within those ducts.
The response to Request 31 was considered to be inadequate for the reasons identified by followup Request 43.
With regard to the response to 50.54(f) Request 34, the buckling stresses due to earth loads, vehicular and railroad traffic, are based on unifonn soil properties. From the pipe profiles, it is apparent that this is not the case.
The responses to 50.54(f) Requests 35 and 37 are inadequate for the reasons stated in A. Schwencer's letter of June 30, 1980 and in " Summary of Aopeals Meeting of August 29, 1980 Regarding Additional Explorations and Testing of Midland Plant Fill," February 10, 1981.
Itens 1 through 8 on an enclosure to a summary of a 1/16/81 meeting are responded to by Consumers answers to Requests 17 and 34.
In regard to the response to Request 17, the criteria does not consider the buckling or crippling stresses due to high bending stresses in the large diameter thin wall piping. Also, there was not sufficient infonnation as to the total piping involved, the proximity of the non-profiled to the profiled piping, L
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. the percentage of piping profiled or soil characteristict in the area of concern. Due to the changes in slope of some of the prof!1ed piping, it would appear that soil characteristics vary.
Again with regard to 50.54(f) Request 17, the rate of change of slope tj or the radius of curvature detennines the bending :tra:.y more than the overall deflection. This request was made on that tOjs. If a satisfactory 4
allowable stress and strain criteria is presented witii en ecergtable stress analysis, the criteria for the change in piping curvature would not be required. The response to Request 34 was previously discussed.
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e TA8LE 8-1 Identity of Whether
Response
Staff's Follow-up Responsible
/
Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Mequacy
. cations as of 2/24/81 l.
8(a) 8(b) 8(c) 8(d) 8(e) 8(g) l 24(a)
Yes Rev. 6, 4/80 Inadequate 47,48,49, R. Gonzales Rev. 6, 4/80 52 R. Lipinski Reponses to NRC Requests Regarding Plant Fill 4
24(b)
Yes Responses to NRC Inadequate 42,47,48 R. Gonzales 3
y Requests Regarding 49,50,51 Corps of Engr.
i Plant Fill 52,53, NRC Interrog-tories 16 to Consumers dated 1/2/81 Rev. 6, 4/80 24(c)
Yes Responses to NRC Inadequate 47,49 R. Gonzales Requests Regarding i
Plant Fill Rev. 6, 4/80 24(d)
Yes Responses to NRC Mequate R. Gonzales Requests Regarding Plant Fill r
I Table 8-1 l
Identity of Whether
Response
Staff's Follow-up Responsible 4
Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations 1
as of 2/24/81
)
8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 1 1
24(d)
Yes Rev. 5, 2/80 Adequate Corps of Engr.;
4 Responses to NRC J. Kane Requests Regarding Plant Fill I
24(e)
Yes Rev. 6, 4/80, Mequate R. Gonzales i
Responses to NRC E
Requests Regarding i
?
Plant Fill l
24(f)
Yes Rev. 6, 4/80, Mequate R. Gonzales j
Responses to NRC a
Requests Regarding Plant Fill 3
24(g)
Yes Rev. 6, 4/80,
'Mequate 36,42,47 R. Gonzales 1
Responses to NRC Requests Regarding i
Plant Fill 24(g)
Yes Rev. 5, 2/80 Inadequate 36,47 Corps of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill 24(h)
Yes Rev. 6, 4/80, Mequate R. Gonzales Responses to NRC Requests Regarding Plant Fill b
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4 Table 8-1 Identity of m ether
Response
Staff's Follow-up
. Responsible Request Consumers Identification Consideration Requests Staff
(
Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations 5
as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) i 24(1)
Yes Rev. 6, 4/80, Adequate R. Gonzales Responses to NRC Requests Regarding Plant Fill 25 Yes Rev. 10, 11/80, Inadequate NRC Interr-F. Rinaldi el Responses to NRC ogatories
- f Requests Regarding 1-9 to f
Plant Fill Consumers, 11/26/80 26 Yes Rev. 5, 2/80, Inadequate NRC Interr-F. Rinaldi Responses to NRC ogatories Requests Regarding 1-9 to Plant Fill Consumers, 11/26/80 27 Yes Rev. 5, 2/80, Adequate Corps of Engr; Responses to NRC J. Kane
[
Requests Regarding Plant Fill f
28 Yes Rev. 5, 2/80, Inadequate NRC Interr-F. Rinaldi Responses to NRC ogatories j
Requests Regarding 1-9 to 1
)
Plant Fill Consumers.
11/26/80 i
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Identity of Whether
Response
Staff's Follow-up Responsible i
Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations L
as of 2/24/81 L
8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 29 Yes Rev. 5, 2/80, Inadequate NRC Interr-F. Rinaldi I
Responses to NRC ogatories Requests Regarding 1-9 to Plant Fill Consumers.
a I
11/26/80 4
30 Yes Rev. 8, 8/80, Adequate F. Rinaldi 7
Responses to NRC Requests Regarding Plant Fill 31 Yes Rev. 5, 2/80, Inadequau 43 Corps. of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill 6
34 Yes Rev. 5, 2/80, Inadequate A. Cappucci l
Responses to NRC Requests Regarding Plant Fill 35 Yes Rev. 9, 9/80, Inadequate 37,40 Corps. of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill t
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Identity of Whether
Response
Staff's Follow-up Responsible j
Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations i
as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 36 Yes Rev. 9, 9/80 Adequate Corps of Engr; Responses to NRC J. Kane Request Regarding Plant Fill 37 Yes Sept. 14, 1980 Inadequate Tedesco letter Corps of Engr; a
Report - Discussion to Cook J. Kane 7
of Applicant's 11/10/80 Position 4-38 Yes Rev. 9, 9/80 Adequate Corps of Engr; Responses to NRC J. Kane i
j Request Regarding Plant Fill 39 Yes Rev. 10, 11/80 under review To be Corps. of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill 40 Yes Rev. 10, 11/80 Under review To be Corps of Engr; ii Responses to NRC determined J. Kane i
Request Regarding l
i Plant Fill I
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Table 8-1
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Identity of Whether
Response
Staff's Follow-up Responsible j
Request Consumers identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel 4
I after 12/6/79 Staff Adequacy cations L.
as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g)
/.
41 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC detemined J. Kane Request Regarding Plant Fill 42 Yes Rev. 10, 11/80 Under review To be Corps of Engr; 1l Responses to NRC determined J. Kane
[
g Request Regarding Plant Fill 43 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill 44 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane i
Request Regarding Plant Fill I
45 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill l
46 Yes Rev. 10, 11/80 Under review To be Corps of Engr; i
Responses to NRC determined J. Kane f
Request Regarding I
6 Plant Fill
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Table 8-1 Identity of Whether
Response
Staff's Follow-up-Pesponsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations i
as of 2/24/81
)
9; 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 4:
47 Yes Rev. 10, 11/80 under review To be Corps of Engr; E
d Responses to NRC determined J. Kane Request Regarding Plant Fill 6-48 Yes Rev. 10, 11/80 under review To be Corps. of Engr; Responses to NRC determined J. Kane i
(
A Request Regarding
?
Plant Fill l
49a Yes Rev.10,11/80 under review Interroga-R. Gonzales l
Responses to NRC tory 16 to
.I Requests Regarding Consumers Plant Fill dated 1/2/81 49b Yes Rev. 10, 11/80 Under review Interroga-R. Gonzales Responses to NRC tory 16 to Requests Regarding Consumers Plant Fill dated 1/2/81 49c Yes Rev. 10, 11/80 under review To be R. Gonales Responses to NRC determined Requests Regarding Plant Fill L
50 Yes Rev. 10, 11/80 Adequate R. Gonzales Responses to NRC Requests Regarding Plant Fill
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t Table 8-1 j
identity of Whether
Response
Staff's Follow-up Responsible ll Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations f
as of 2/24/81 I
8(a) 8(b) 8(c) 8(d) 8(e) 8(g) n 1
51 Yes Rev. 10, 11/80 Under review Interroga-R. Gonzales Responses to NRC tory 15 to Requests Regarding Consumers Plant Fill dated 1/2/81 52 Yes Rev. 10, 11/80 under review To be R. Gonzales M
Responses to RRC detemined Requests Regarding Plant Fill I
53 Yes Rev. 10, 11/80 Under review To be R. Gonzales j
Responses to NRC detemined, Requests Regarding Plant Fill Items 1-3 of Yes 17, revision 5; Inadequate Conference A. Cappucci to Callo{,
Summary of 9/8/80J 1/16/80 34 revision 5 Inadequate Conference A. Cappucci I
- meeting, call o 9/8/80{=f 2/4/80 If W. P. Chen Exhibit 7. Oral Deposition of January 21, 1981.
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Table 8-1 I
Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff I
Responded Reviewed by of Response or Communi-
_ Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g)
?
Item 4 of No 17, revision 5 Inadequate Conference A. Cappucci
).
Call o 4
9/8/80{f to Summary
=
of 1/16/80
- Meeting, A
2/4/80 Items 5-8 Yes 17, revision 5 Inadequate Conference A. Caopucci of Enclosure Callo{2-f 3 to Summary 9/8/80 of 1/16/80 j.
- meeting, 34, revision 5 Inadequate Conference A. Cappucci 2/4/80 Callo{9/8/8M NRC Inter-Not yet None Not received None F. Rinaldi rogatories to Consumers 1-9, November 26, 1980 NRC Interr-I ogatories to Consumers j
1/2/81:
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-Table 8-1 I
Identity of idhether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e)
~
8(g)
Interr. 1 Not Yet None Not received None A. Cappucci i
l Interr. 10,11 Not Yet None Not received None J. Kane a
4
- D. Hood Interr. 15,16 Not yet None Not received None R. Gonzales h
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1 Interrogatory 9 Excluding the infonnation provided in response to interrogatory 5, state with particularity each item of information the Staff felt was nec-essary, as of December 6,1979, for Consumers to provide in crder for the Staff to have concluded that "the safety issues associated with remedial action taken or planned to be taken by the licensee to correct the soil deficiencies will be resolved." (Order at page 3).
Answer As of December 6,1979 the Staff had detennined that, because the Licensee had failed to supply certain acceptance criteria, it could not conclude that the safety issues associated with remedial action taken or planned to be taken to correct the soil deficiencies would be resolved. The Staff had not detennined, as of December 6,1979 "each item of information the Staff felt was necessary, as of December 6,1979 for Consumers to provide y
in order for the Staff to have concluded that the safety issues associated e
with remedial action taken or planned to be taken by the licensee to correct L
the soil deficiencies will be resolved' Order at page 3."
See also discussion of need for seismological information in answer ti Interrogatory 11.
The infonnation the Staff felt was necessary, as of December 6,1979
(
was essentially that identified in answer to Interrogatories 2 and 5, in-cluding Appendix A relative to acceptance criteria. It shoted be noted.
u 9
however, that prior to December 6,1979, the full extent of the plant fill settlement problem was unknown and was under review. For example, 50.54(f) i Request 12 from H. Denton letter of March 21, 1979 asked for documentation l
l l
l
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l of the condition of the soils under all safety related structures and utili-ties founded on plant fill or natural lacustrine deposits. This same request asked for discussions of measures to be taken if foundation materials are found to be deficient. Const ** ' response to Request 12 (initially on p
April 24, 1979 and subsequently oy Revision 1 on May 31,1979, Revision 2 on July 9,1979, and Revision 3 on September 13,1979) provided infonnation which the Staff found not to be fully responsive and, therefore, unacceptable.
The basis for the Staff's conclusion on acceptability is illustrated by the issuance of followup requests which seek to have Consumers provide its design and criteria in sufficient detail to enable the Staff to conclude l
whether there is reasonable assurance of plant safety considering those ll' modifications. An example of this problem is illustrated by the issuance of Requests 41 and 42 by the Staff's letter of August 4,1980 in which the Staff's geotechnical consultant, the U.S. Amy Corps of Engineers, continue t
to seek basic infonnation and data not previously provided in Consumers responses regarding the fixes proposed for the Service Water Intake Struc-ture and the Auxiliary Building which the Staff needs to reach a conclusion on the acceptability of plant repairs.
l Certain items of infonnation, in addition to that provided in response N elt to be needed by the Staff to interrogatories 2 and 5 were probably f
[
4/
The initial staff reviewer in the Mechanical Engineering Branch (MEB),
i Mr. R. Stephens, is no longer employed with the NRC. The items identi-fled reflect the opinion or recollection of the subsequent and present MEB Staff reviewed. Mr. A. Cappucci, from earlier personal discussions l
and notes.
It is not known how or whether any of these possible needs may have been conveyed to Consumers.
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Prior to December 6,1979 with respect to underground piping and associated components. The items are that:
r (a) All the seismic Category I piping be profiled.
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(b) Remedial action be specified for the case in which stresses due to settlement should approach or exceed Code allowable values.
(c) Details as to the calculational methods and assumptions for deter-
~I mining stresses due to settlement and other combined loads be 1
1 provided for review.
l (d) Results of the stress analysis of nozzle loads be submitted.
7 (e) A suitable monitoring program be established to monitor future
}
settlement for the life of the plant.
(f) Future settlements be included in the planned stress analyses.
i Interrogatory 10 For each item of infomation set forth in response to interrogatory 9, state (a) whether the Staff had requested Consumers to provide such infoma-tion; (b) the identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response to the request; (d) whether Consumers' response was deemed adequate by the Staff; (e) the identity of the connunication by which the Staff's evaluation of Consumers' response was communicated to Consumers; (f) the basis for the c
[
Staff's position regarding adequacy or inadequacy of Consumers' response; e
and (g) the Staff personnel responsible for detemining whether Consumers' response was adequate or inadequate.
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Answer See answer to Interrogatory 9. Because the infonnation the Staff felt was necessary as of December 6,1979 was essentially that identified in answer to Interrogatories 2 and 5. -the answer to interrogatory 10 is essen-i tially provided by the answers to Interrogatory 6, including Appendix B, and by that part of Interrogatory 8 relevant to indicated Requests 24 through 35.
With respect to certain items of infonnation (a) through (f) identified in the answer to Interrogatory 9 with respect to underground piping and associated components, the answer to Interrogatory 10 is provided by Table 10-1.
l The answer to Interrogatory 10(f) follows.
f (a) The criteria for selection of the piping to be profiled appears to i
be based on the soils in the same proximity as being homogeneous.
There appears to be insufficient evidence that this is the case.
(b) Theresponse'to50.54(f) Request 17 stated that the stresses due to settlement would be well below the code allowable values as indicated in Table 17-2 of that response. Therefore, it was indi-cated that reedial action was not planned by Consumers. This is not adequate because (1) not all seismic Category 1 piping was profiled. (2) future settlements had not been predicted, and (3) the results of the surcharge program had not been established.
(e) The response to 50.54(f) Request 18 in July 1979 indicated no plans for a monitoring program if the settlements remain within the predicted range.
It was not clear as to the time frame and methuds for verifying the predicted ranges.
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s (f) The response to 53.54(f) Request 17 provided no information on E
T settlements over plant lifetime. The response to 50.54(f) Request 18 was abequate.2 The response to 50.54(f) Request 19 provided no F
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information as to the predicted deforinations.
y, I.pttrrogatory 11 t
I Excluding the information provided in response to interrogatory 7, 4
I state with particularity each item of information the Staff feels, as of the h
date of answering this interrogatory, is necessary for Consumers to provide in order for, the Staff to conclude that "the safety issues associated with remedici sction taken or planned to be taken by the licensee to correct the soil deficiencies will be resolved." (Order at page 3.)
Answer The Staff has not completed its review of information submitted by Licensee relative to the proposed remedial actions.
It is therefore impossi-ble to delineate "with particularity each item of infomation the Staff feels, as of the date of answering this interrogatory, is necessary for 4
ConsumeT to prraide in order for the Staff to conclude that 'the safety issues associated with remedial action taken or planned be taken by the licensee to correct the soil deficiencies will be resolved.'
(Order at page3.)"
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I ij TABLE 10-1 Item from Whether Staff Identity of
Response
Staff's Con-How Position Responsible Interr.
Requested Request Identification sideration of Conveyed to Staff 9
Information 10(b) 10(c)
Response
Consumers Personnel 10(a)
Adequacy 10(e)
(10(g) 10(d) 9(a)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens l
Request 17, quest 17. Rev.
A. Cappucci i
Denton 3/21/79 2, 7/79, Res-ponses to NRC Requests Re-i garding Plant Fill 9(b)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17 quest 17. Rev.
A.
c)
Denton 3/21/79 2, 7/79, Respon-a ses to NRC Re-quests Regard-ing Plant Fill 9(b)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17 quest 17, Rev.
A. Cappucci Denton 3/21/79 2, 7/79, Respon-ses to NRC Re-quests Regard-ing Plant Fill 9(c)
No None Mone Not applicable Not applic-R. Stephens A. Cappucci 9(d)
No None None Not applicable Not applic-R. Stephens
-ble A. Cappucci i
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t Item from Whether Staff Identity of
Response
Staff's Con-How Position Responsible 1
Interr.
Requested Request Identification sideration of Conveyed to Staff.
a 9
Information 10(b) 10(c)
Response
Consumers Personnel e
h 10(a) 10(e)
(10(g)
L Adequacy) 10(d 9(e)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 18 quest 18. Rev.
A. Cappucci 2,7/79, Responses to NRC Requests Regarding Plant Fill L,
c 9(f)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens 1(
Requests 17, quests 17, 18 A. Cappucci J_
18 and 19 and 19. Rev. 2 af 7/79, Responses to NRC Requests Re-garding Plant Fill 4
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0 To illustrate this inability, consider two recent occurrences:
(1)On t
January 21, 1981 Consumers submitted a potentially reportable 50.55(e) g report advising of an error in the 1977 computer model used for the seismic
?
analyses of the Control Tower and the main portion of the Auxiliary Building.
y Pending further analysis by Consumers, it is not possible for the NRC to 4
assess the ability of the Control Tower to assume the additional load result-ing from the bridged support scheme proposed for the Electrical Penetration Area; (2) Consumers has also indicated that additional cracking of the m
g concrete ring base of the Borated Water Storage Tank has occurred during the full scale load test. The Staff is presently awaiting Consumers' assessment of this occurrence. It should also be noted that resolution of the matter of establishing appropriate seismological input, as discussed in th'e Staff's
(
letter of Octolpr 14, 1980 and in a December 22,1980 " Summary of December 5,1980 Mee'ing on Seismic Input Parameters," is deemed to be relevant to t
the staff conclusion that the safety issues associated with remedial action taken or planned will be resolved.
The infomation needed by the staff for its review of the remedial t
actions is essentially that identified in response to interrogatories 2, 6, l
7 and 8, plus Appendices A and B, with respect to acceptance criteria for
[
those response items indicated to be inadequate. In Table 6-1 and Aoppendix A, the indication of response adequacy by the staff is with respect to December 6, 1979. However, the present staff position may be ascertained from the indicated disposition of the associated follow-up questions. The occurrences and seismic matter discussed in Interrogatory 11 also needs to be satisfactorily resolved, i
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D from interrogatory 7, the following information is needed:
(a) A final stress analysis of the seismic Category I piping.
(b) An explanation for some of the relatively rapid changes in some of
/
the piping profiles and the magnitude of the loads which cause h
these changes.
R (c) The actual and predicted clearances at end of plant life of seismic Category I piping at building penetrations.
3 (d) The loads and stresses on the piping at their termination points (anchors, equipment, larger pipe, etc.).
(e) From the January 20, 1981 meeting, provide method and basis for nomalizing the profile data prior to perfoming the stress analysis and use of 3-inch future settlement data.
If a non-linear analysis is to be perfonned, provide the analysis methodology with a sumary of the results.
Include a presentation of the margin to the Code allowable value for settlement only and the same for the margin to failure considering all primary and secondary stresses.
Interrogatory 12 For each item of infomation set forth in response to interrogatory 11 state: (a) whether the Staff had requested Consumers to provide such infor-mation; (b) the identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response; (d) whether Consumers' response was deemed adequate by the Staff; (e) the identity of the communication by which the Staff's evaluation of Consumers'
}
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4 TABLE 12-1 e
l TABLE 12-1 6
l Interr.11 Wiether Staff Request
Response
Adequacy How Disp.
Responsible Item Requested Identifi-Identity Dis sition Consnuni-Staff Consumers cation 12(c) 12d) cated to Personnel 12(a) 12(b)
Consumers (12(f)
(12fe) 11a Yes Tedesco Cook letter Inadequate Conference A. Cappucci 4
letter 11/14/80 with call 1/14/81 J. Branumer 10/20/80 encl.
11 b,c & d Yes Meeting of No response No response No response A. Cappucci 1/20/81 J. Bransner l'
11e In progress Not Abplicable None Not appl.
Not app.
A. Cappucci j
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response was communicated to Consumers; (f) the basis for the Staff's posi-tion regarding adequacy or inadequacy of Consumers' response; and (g) the Staff personnel responsible for determining whether Consumers' response was adequate or inadequate.
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Answer See answer to Interrogatory 11. With respect to the information needed with respect to underground piping, see Table 12-1.
With respect to the adequacy of iten 11a on Table 12-1, the Bechtel stress analysis appeared to be unconservative and did not give a true repre-1 l.
sentation of the actual stress in piping. There were questions as to which I
l profiles were used and the. justification for the boundary conditions assumed.
An ETEC stress analysis demonstrated much higher stresses than those in the Bechtel report. At the 1/20/81 meeting Bechtel stated that subsequent analyses had shown higher stresses for some lines.
Interrogatories 13 through 16. See separate objections filed by the Staff.
b Interrogatory 17 Explain and provide the basis for the statement at page 2 of the Order l
tnat "This statement is material in that this..ortion 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 controlled compacted cohesive fill as stated in the FSAR."
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Answer Information submitted as part of an application for licenses in accord-ance with 10 CFR 50.30 is " material" if that information would or could have an influence upon a safety conclusion of the NRR Staff. A material statement which is false is of concern if it could have resulted in an improper finding or a less probing analysis by the NRR Staff. As described on page 2 and i
Appendix B of the Order, had the NRR Staff relied upon the statement in FSAR Section 2.5.4.5.3 which states that "all fill and backfill were placed according to Table 2.5-9", it would or could have erroneously concluded that the fills and backfill placed for the support of structures and the Diesel Generator Building consisted of " clay" (Table 2.5-9 under " Soil Types") or
" Controlled compacted cohesive fill" (Table 2.5-14 under " Supporting Soils")
which had been compacted, as a minimum, to 95% of ASTM D 1557-66 T modified to get 20,000 foot-pounds of compactive energy per cubic foot of soil (see Table 2.5-9 under " Compaction Criteria"). The reality of the situation is that the fills and backfills beneath the structures and the Diesel Generator
~
Building are not " clay" or a " controlled compacted cohesive fill", but consist of a heterogeneous ciAture of sand, Clay, silt and lean Concrete, and the minimum compaction criteria implied as having been achieved by the quoted statement from FSAR Section 2.5.4.5.3 was not achieved. Therefore, a conclusion by the Staff that the fills and backfills were of a different l'
type or had been compacted to known minimum standards would have been erro-neous and would or could contribute to or preclude a more probing analysis
!~
or further questioning. Based upon the FSAR infomation, the Staff would or could have concluded that the structure was adequately supported, that it L
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.- would not experience detrimental settlement, that its foundations would l
remain stable under both static and earthquake loading, and that the fill N
properties would be at least equal to design values provided in the PSAR.
The Staff's conclusion would have been relevant to the NRC findings pursuant to 10 CFR 50.57 (3) for issuance of operating licenses and would have con-tributed to a finding that there is reasonable assurance that the activities
. 1 authorized by the operating license can be conducted without endangering the d
health and safety of the public.
k.
Darl Hood, being duly sworn, states that to the best of his knowledge and belief the above information and the answers to the above interroga-f tories are true and correct.
I l
hh fl778 Darl Hood Subscribed and sworn to before me this 2S'9ay of February,1981.
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Commission Expires:
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-n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of C0;!SUMERS POWER C0ilPANY Occket Nos. 50-329-0M & OL 50-330-0M & OL (MidlandPlant, Units 1and2)
CERTIFICATE OF SERVICE
~
I hereby certify that copies of NRC STAFF'S ANSWERS TO INTERROGATORIES FILED BY CONSUMERS POWER COMPANY in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 25th day of February,1981.
I
- Charles Bechhoefer, Esq.
Ms. Mary Sinclair j
Atomic Safety and Licensing Board 5711 Sumerset Street l
U. S. Nuclear Regulatory Comission Midland, Michigan 48640 Washington, D.C.
20555
- Mr. Gustave A. Linenberger Michael I. Miller, Esq.
Atomic Safety and Licensing Board Ronald G. 7amarin, Esq.
U. S. Nuclear Regulatory Comission Alan S. Farnell, Esq.
Washington, D.C.
20555 Isham, Lincoln & Beale One First National Plaza Dr. Frederick P. Ccwan 42nd Floor 6152 N. Verde Trail Chicago, Illinois 60603 Apt. B-125 Boca Raton, Florida 33433
- Atomi,: Safety and Licensing Board Panel Frank J. Kelley U. S. Nuclear Regulatory Comission Attorney General of the State Washington, D.C.
20553 of Michigan Steward H. Freeman
- Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel Gregory T. Taylor U. S. Nuclear Regulatory Comission Assistant Attorney General.
Washington, D.C.
20555 Environmental Protection Division 720 Law Building
- Docketing and Service Section Lansing, Michigan 48913 Office of the Secretary U. S. Nuclear Regulatory Comission Myron M. Cherry, Esq.
Washington, D.C.
20555 1 IBM l'laza Chicago, Illinois 60611
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James E. Brunner, Esq.
Jeann Linsley Consumers Power Company Bay City Times 212 West Michigan Avenue 311 Fifth Street Jackson, Michigan 49201 Bay City, Michigan 48706 R. Barbara Stamiris 5/95 N. River Freciand, Michigan 48623 Mr. Steve Gadler 2120 Carter-Avenue St. Paul, Minnesota 55108 l
Wandell H. Marshall, Vice President Midwest Environmental Protection Associates RFD 10 Midland, Michigan 48640 3
James R. Kates 203 S. Washington Avenue Saginaw, Michigan 48605 -
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William D. Paten Counsel for NRC Staff a-
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.c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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.t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
4 In the Matter of
)
50-330 OM & OL CONSUMERS POWER COMPANY (Midland Plant Units 1 and 2)
NRC STAFF TESTIMONY OF DARL HOOD, JOSEPH KANE.
FRMHHtfftAtiH AND EUGENE GALLAGHER ON STAMIRIS CONTENTION 2 7
Q.1.
Please state your names and positions with the NRC.
t l
A.
My name is Darl Hood.
I am a Senior Project Manager in i
the Division of Licensing Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission.
My name is Joseph Kane.
I am a Principal Geotechnical f*
'l Engineer within the Hydrologic and Geotechnical Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation, U.S.
s Nuclear Regulatory Commission, l
J i
Pty name is Frank Rinaldi.
I am a Senior Strmetural Engi-1
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neer in the Structural. Engineering Branch, Division of Engineering,
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Office of Nuclear Re, actor-RegulatTo'n, UANuclear Regulatory 3
Commission.
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% name is Eugene Gallagher.
I am a civil engineer with the U.S. Nuclear Regulatory Connission. Since February 1981, I
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have been assigned to the Reactor Engineering Branch, Division of ggad Resident and Regional Reactor Inspection, Office of Inspection and b
C gIhhlY Enforcement. Prior to February 1981, I was a reactor inspector s
4
~l assigned to the Region III, Reactor Construction and Engineering i
Support Branch, Office of Inspection and Enforcement.
J, Q.2.
Have you prepared a statement of professional qualifications?
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A.
Yes. Copies of these statements are found in Attachment 1.
Q.3.
Please state the duration and nature of your responsibilities with respect to the Midland Plant, Units 1 and 2?
A.
I, Darl Hood, am the Project Manager for the Midland Plant
,i application for operating licenses. I have served in that position
' j, from August 29, 1977, when the application for operating licenses was tendered to the NRC for acceptance review, up to the present l.
time. My responsibilities include management of the Staff's
! t environmental and radiological safety reviews.
I am responsible bM'b for the responses to Stamfris Contention 2(a), (d),
an supple-l}
mentary Items 1, 6,10 and 12.
u I, Eugene Gallagher, was assigned to the Midland Plant
'l (among others) from October 1978 until January 1981. Since October I
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of 1978, I have spent approximately 1 year of effort perfonning q.
inspections, reviewing quality control records and procedures, observing work activities, reviewing Consumers Power Company's (hereafter CPC or Applicant) response to 50.54(f) questions 1 and j
23, and attending meetings and presentations by CPC and Bechtel
]
regarding the soil settlement matter of the Midland Plant.
I am 4
responsible for the response to Stamirts Contention 2(c).
t I, Joseph Xane, have served since November 1979 as the l
technical moriitor for the Midland portion of an interagency contractual agreement between the NRC and the U.S. Army Corps of Engineers, Detroit District (hereafter the Corps). By this contract
+
the Corps has been assisting the NRC Staff in the safety review of the Midland Project in the field of geotechnical engineering.
In addition to, and as a consequence of, my serving as contract tech-nical monitor, I have become directly involved in the assessment of the adequacy of the remedial measures which have been proposed by CPC to correct the plant fill settlement problem.
I am responsible for the responses to Items 2, 3, 4, 5, 7, 8, 9 and 11 of Stamiris' ij supplement to Contention 2.
a i
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I rank Rinaldi, have served since Februar as the
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technical monitor for he Midland portion of nteragency con-
- I tractual agreement between the.
.an the Naval Service Weapons j
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f Center (hereafter NSWC).-By this contrachthe NSWC has been i
assisting. the NRC Staff in the safety review o TineProject a
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~'tQffeld of structural _ engineering.
In addition to, and as-a'~
of my serving as contract technic ave conseque l-become directly i eAin the assessment-of the adequacy of the N /' d by CPC to correct the l
remedial measures which have ropose plant fill setti problem.
I am respo ble for th'e response 1
l to It Stamiris' supplement to Contention 2.
i T
Q.4.
Please state the purpose of this testimony.
J.
A.
The purpose of this testimony is to address Stamiris Contention 2 as stated in the Appendix to "Prehearing Conference Order Ruling on Contentions and on Consolidation of Proceedings (October 24,1980)," and as supplemented by Ms. Stamf ris in "Intervenor Answer to Applicant's Interrogatories, 4/20/8 g gn
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?(3 m the-pacties aaruLthe;. di eyeiaa a# raat atia-aartpWo the August portion of the hearina_
Stamiris Contention 2 reads as follows:
s N
Consumers Power Company's financial and time schedule pressures have directly and adversely affectM resolu-tion of soil settlement issues, which constitutes a com-li promise of applicable health and safety regulations as
- ,j denonstrated by:
,.g f;:
a) the admission (in response to 950.54(f) question #1 Q requesting identification of deficiencies which i
l.1 contributed to soil settlement problems) that the t i FSAR was submitted early due to forecasted OL 1
intervention, before some of the material required t
to be included was available; l
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-s-b) the choice of remedial actions being based in part PM' on expediency, as noted in Consumers Power Company @O M consultant R. B. Peck's statement of 8-10-79; c) the oractice of substituting materials fnr those Mhtr' originally specified for " commercial reasons" (NCR QF203) or expediency, as in the use of concrete in electrical duct banks (p. 23 Kappler Report)*;
d) continued work on the diesel generator building while bd i
unresolved safety issues axisted, which precluded thorough consideration of Option 2 - Removal and Replacement Plan; and e) the failure to freely comply with NRC testing bh requests to further evaluate soil settlements remediation, inasmuch as such programs are not allowed time for in the new completion schedule presented July 29, 1980.
April 20, 1981 Supplement to Contention 2 Further examples of the effect of financial and time pressures on soil settlement issues:
Examples Effect on soil settlement issues b.
- 1. 11/7/78 Bechtel action
- 1. Root causes not adeq. investigated, i
p.1 item:" proceed with prepara-Organizational deficiencies not O,(4%
tions for preload as rapidly eliminated prior to proceeding as possible" with remediation gg
- 2. 11/7/78 decision to fill
- 2. Affected piezometric measurements
- Ont, Ng4 pond "immediately, because the during preload 3.Th\\d amount of river water avail-able for filling is restricted" 1
Pec.t 3,11f7f78 5 month period
- 3. The surcharge was removed at the &c.
f3.M is available in the schedule end of this 5 months despite
,16,%
for preloading" lack of NRC satisfaction that i-secondary consolidation was I;
assured
)
j i
I March 22, 1979 Xeppler Investigation Report conducted by Region III, l
Dec. 78-Jan. 79.
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- 4. Failure to grout gaps
- 4. Resulted in additional stresses b Emdk prior to cutting of duct to DGB which could have been g,l g g banks, failure to cut con-avoided a
densate lines when first suggested, failure to break up mudmat at OGB
- 5. Eliminated practical consideration bhf. U*
- 5. Choice to continue construction of DGB of Removal & Replacement Option
- 6. Early FSAR submittal
- 6. Precluded early detection of
{y.W and inadequate review inconsistencies which could have of FSAR prevented some of the s.s. problems kwg b,$
- 7. Failure to reconstruct
- 7. Varying degrees of caution and geometry of area prior to conservatism were foregone in i
fill placement, failure to favor of cost and schedule await NRC approval before advantages i
proceeding with Preload, selection of "least costly feasible alternative" for DGB.
bx-;
- 8. Failure to excavate loose
- 8. Contributed to inadequacy Nonf 73 U sands as committed to in PSAR of subsoils NQhf. b M
- 9. Installation of preload
- 9. Expenditures for preload instrumentation was* subject instrumentation (CJD 11/1/78 to time pressure assoc. with memo) prior to formal adoption frost protection considerations of preload = premature commitment
- 10. Appeals to NRC to consider
- 10. If granted, would affect 00 financial plight and schedule seismic--soil settlement deadlines as in Seismic standards Deferral Motion kH9,g.21 kCg.
- 11. Depth and breadth of
- 11. Afforded less than optimum O,if surcharge limited by practical conditions for surcharge consideration of OG8, Turbine B.
structures
- 12. Changes to design (DGB foun-12. Contributed to settlement or h
dation), material, or proceedural stress problems and allowed specifications without proper conflicts to go unnoticed as
~j approval preventative indicators Q.5 What is the NRC Staff response to Stamiris Contention 2(a)?
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1 I I A.
First, the statement which Contention 2(a) calls an "admis-j-
sion" is found in the third paragraph of CPC's response to 50.54(f)
,8 Request 1 Part b (page 1-2 of Responses to NRC Requests Regarding
.-j Plant Fill). That full paragraph which is a part of the Applicant's l
i
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explanation regarding contradictions between the PSAR and.the FSAR reads as follows:
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The Midland FSAR was submitted to the NRC at an earlier point in the project schedule than would have nonnally occurred in
,j order to provide additional time for the operating license hearings due to the forecasted intervention. Consequently, o
some of the material required to be included in the FSAR was not available at the time of its initial submittal, or was supplied based upon preliminary design infonnation. As the design and construction continued, the appropriate sections of the FSAR were revised or updated to include the necessary information.
I Second, a portion of the application for operating licenses,
'i namely the FSAR, was tendered by CPC on August 29, 1977. The NRC l{
performed an acceptance review pursuant to Section 2.101 of 10 CFR J
("
Part 2, and by letter dated November 11, 1977 advised the Applicant l
that the tendered FSAR was sufficiently complete based upon all of Ll l'
the information filed, taken as a whole. The Midland FSAR was h
docketed on November 18, 1977. The remainder of the application,
'j namely the Environmental Report, was tendered March 1,1978 and 2
1 docketed April 14, 1978.
I u
i Third, the original schedule approved by NRC in December 1977
)
was based upon a projected fuel load date of October 1,1980 for Unit 2.
The major licensing milestones scheduled for the FSAR review
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were:
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-4 FSAR docketed 11/18/77 Safety Evaluation Report s
(SER) issued 3/30/79 ACRS Meeting 5/10/79 Supplement to SER issued 7/13/79 Start OL hearing 8/13/79 End OL hearing 7/15/80 Decision 10/1/8C I
It is not unusual for the Staff to initiate review of an FSAR l
{
without inclusion of all the material which will ultimately be required for completion of that review. Moreover, the difficulty associated with certain statements made in the FSAR was not a matter i
of information excluded from the early versions of the FSAR, but rather a matter of their accuracy.
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A, decision by the NRC to docket an FSAR and the establishment of review schedules are administrative matters for which the NRC's goal is to provide for completion of the licensing review consistent with the construction schedule. With respect to the Applicant's statement that "some of the material required to be included in the FSAR....was supplied based upon preliminary design information " the obligation of the Applicant to provide accurate infonnation under oath or affirmation pursuant to Section 50.30 to 10 CFR Part 50 is l
by no means waived by these administrative matters, regardless of when they occur. Similarly, the quality assurance requirements of
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Appendix 8 to 10 CFR Part 50 which are applicable to the FSAR apply irrepective of any time table.
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For these reasons, the early submittal of the FSAR provides no justification for the deficiencies associated with soil settlement problems, nor does it constitute a compromise of applicable health
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j and safety regulations.
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j-Q.6.
What is the NRC. Staff response to Stamf ris Contention 2(c)?
e 4
A.
NCR QF 203 (Attachment 2) identifies three instances i
where user test reports for1ranular soil material did not meet specification gradation limits.
(1) User Test Report 0630:
the acceptance gradation Ifmits for material passing the sieve were 90%; the user test report showed 94% passing. This deviation was " accepted as is" based on engineering review of the actual gradation of the material supplied.
(2) User Test Report 1036: the acceptance gradation limits for material passing the h" sieve were 75-90%; the user test showed 91%. This deviation was rejected based on an engineering i
l review and material was not permitted to be used in "Q" areas, but l
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the material was permitted to be used in non "Q" areas.
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Il (3) User Test Report 0836: the acceptance gradation f
limits for material passing the #200 sieve were 12% - 20%; the user b
test showed 11%. The reason given for the 12% - 20% acceptance L
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criteria was for '"commerical reasons" since the supplier could 1
supply material within these limits. The specification, however, F
l permitted material to be within 7 - 205. Therefore, the acceptance criteria or the user test report was more restrictive than the j
specification requirements.
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d In all three cases the in-process corrective action was acceptable based on a review of the facts. These three noncon-faming conditions did not adversely or directly affect resolution y
-.' s of the soil settlement issue.
Regarding the use of concrete for " expediency" in the electri-cal duct banks. area the following should be considered. Based on i
the IE investigation the lean concrete material in itself was not a matter of concern. The matter of concern was that the design controls did not verify if the substitution of concrete in this area would affect the design basis of the structure (i.e. interface between the electrical duct banks and the Diesel Generator Building settlement). The IE investigation found that the design interface and consideration between electrical and civil was not adequate to assure the necessary tolerance between the duct banks and the i
.i structure to provide free movements when settlements occurred.
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The question of expediency was not the issue in IE investigation 1
-j report 78-20, but rather the issue was the adequacy of the design coordination.
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1 j-Q.7 L What is the i;EC Staff response to Stamiris Contention 2(d)?
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The Staff does not agree that continued work on the Ofesel
.j Generator Building foreclosed consideration of the removal and f
replacement option as a viable alternative.
Indeed, that option
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remains viable today should that option prove necessary. As noted
./
in the Applicant's response to 50.54(f) Request 21, the continuation
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of building construction would contribute to the additional costs
- i for implementing the removal and replacement option in the event the j
elected preload plan should fail to provide acceptable results.
Such financial matters undertaken at the Applicant's own risk would
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not deter the NRC from requiring an acceptable solution in the event of unacceptable results from the option implemented.
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Q.8.
What is the NRC Staff response to Stamiris' Contention 2(e)?
v A.
"new completion schedule" referred to in Contention 2(e) !M
'l was presented'bECPC during the meeting of the NRC's Caseload Fore-I
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g cast Panel in Midland',' Michigan on, July 29, 1980, to assess the N
construction completion sc TaQ r Midland Plant, Units 1 and 2.
The new estimate for completion of Unt(2 was July 1983, and for l -
Unit I was December /
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1983. The correspondin'g dates for commercial
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operation were December 1983 and July 1984 (steam' operation),
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___.-._..__-_.i The Staff assumes that the "NRC testing requests" state N
Conte'ntion 2(e) refer to the June 30, 1980 Staff reque I
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d (Request 37) for additional borings and laboratory /
analyses.
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.i The NRC Staff knows of no basis for Stamiris' statement that tM j
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the new completion schedul does not aHow time for testing programs 3
1 to further evaluate soil sett ament remediation. Furthermore, it cannot recall any such statemen't the Applicant at the July 29,
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N 1980, meeting nor at any,other time. Rath, it is the Staff's understanding that the results of laboratory analges of the borings q
as requested by NRC' and the Corps, will be provided ing in mid-June 1981 This timetable is compatible with the completion schedule,as presented July 29, 1980.
/
Q.9.
What is the NRC Staff response to Item I in Stamiris' supplement to Contention 27 E
A.
The "11/7/78, Bechtel action item" cited in Item 1 of "f
Stamfris' supplement to Contention 2 refers to " Meeting Notes No. 882" o(A of Mr. B. C. McConnel of Bechtel for a November 7,1978 meeting ~ g between CPC, Bechtel and Bechtel's consultants. The meeting notes fl l are located at Tab-12, Volume 4 of " Responses to NRC Requests Regard-s.; ing Plant Fill" (Attachment 3). The action iten appears to result 3 from the discussion at page 2 of the meeting notes indicating that a 5-month period was available in the schedule, and that Dr. Peck A - t .T*: - ~r:m'*r :: C. rn
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(i reconnended proceeding with the instrumentation and preload as -lq rapidly as possible. Y d Ms. Stamiris is correct that matters of relevance to the quality assurance program, which include investigations as to the ]. root causes of the soil settlement and reviews of organizatforfal d structures for potential deficiencies, were not completed as of -I ,.j November 7,1978, nor prior to proceeding with the preload program for the Diesel Generator Building. The Staff had expressed a j similar concern during the meeting of December 4,1978, as noted I at the end of the " Summary of December 4,1978, Meeting on Structural Settlement," January 12, 1979: The staff also stated that while attention to remedial action i' is important, detemination of the exact cause is also quite important for verifying the adequacy of the remedial action, j assessing the extent of the matter relative to other structures, j and in precluding repetition of such matters in the future. The Staff's 50-54(f) Request I which was issued March 21, 1979, 4 also noted the Staff's concern that such quality assurance reviews be perfomed. This was followed by 50.54(f) Request 23 on Septem- ./j ber 11,1979. The Staff's concern for quality assurance was a 1 significant factor in the HRC's decision to issue the December 6, ~ 1 1979 Order Modifying Construction Permits. .i ) 1 Q.10. What is the NRC Staff response to Item 2 in Stamiris' supplement to C= tantion 27 M 1 L t \\ 5 1-, e
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.p ' t, ..I7 gj' - '} A. The Staff agrees with Stamiris Contention 2 Item 2, to j the extent that CPC's decision to fill the cooling pond "insnediately, h because of the amount of river water available for filling is restricted," did affect the piezometric measurements during pre-3 loading. This statement was made in the November 7,1978. Meeting 4 ~ i %L2. Notes referred to in the preceding response. (Attacliment 3). The O; coincident effects on piezametric monitoring caused by seepage still developing from the raised pond and also due to the development of Chsggi excess pore water pressures under the surcharge loading were identi-hvit. fled by the Staff (Attactim,W)'k Wa NE h CfL cvdcW%M47 and its c -9eC4 <ht bh 4 en W w. being an important reason for not being able to fully accept CPC's conclusion on the-effectiveness of the surcharge progrsm. To overcome this problem, the NRC has attempted to have the effectiveness of the l surcharge program verified by requiring the additional borings and i laboratory testing for the Diesel Generator Building foundation soils. [ tQ er % ' % % di 3 y, 2. t n ma.w w, W 4 y,,a at " f* ^'k The Staff would agree that time schedule /prehIrdId'd MT 9" CPC to accept less than the best sequence in the pond raising-surcharge placement operations and therefore, these pressures may have adversely affected resolution of the soil settlement issues. 't. + .h Q.11. What is the NRC Staff response to Item 3 in Stamiris' supplement I,j l. kt,(,h - %%L to Contention 27 f{ l i i i i 9
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,j I j} - q i A. The Staff agrees with Stamiris that the minutes of the meeting held Nov' ember 7,1978, between CPC, Bechtel and Bechtel's gch,gd 3 1 consultants does indicate "a 5-month period is available in the " ('f1 j schedule for preloading." The Staff also agrees with the Stiamiris contention that the surcharge was removed without NRC being
- ,j satisfied that secondary consolidation was assured. The Staff
- j acknowledges, however, that CPC did notify the NRC of its intention to remove the surcharge fill prior to actually removing it.
d h D 'y b
- I The reasons the Staff was not satisfied with the effectiveness i
of the surcharge program can be traced to CPC's former practice of G not identifying the criteria that would be acceptable to the NRC s i Staff in advance of completing the remedial action. CPC's practice s .j, ] and the resulting difficulty that it presented to the Staff is { illustrated in the following paragraph taken from the Sunniary of 4 ,j July 18, 1979, Meeting on Soil Deficiencies at the Midland Plant Site" (Attachment 5):TetMi T Ow+dT The staff noted that the response to its 10 CFR 50.54 q requests for acceptance criteria for remedial actions (e.g., M.'24.hp questions 4, 6. etc.) had not resulted in identification
- J of criteria in advance of the remedial action. Rather the y
reply notes that the criteria will be determined during or L.I after the remedial action. The staff stated that this H approach by the applicant does not provide for timely staff .l. feedback at the outset, but rather the staff must await results of the program to detennine what acceptance criteria were used and if they are acceptable. Thus, the remedial { action is being conducted entirely at the applicant's own risk. i i 1 l =9
k,,.. m. j 1] ,q. The Staff's conclusions as to whether secondary consolidation had been reached due to the surcharge program and as to the effec-4 tiveness of the surcharge program awaits receipt and review of the - 4 results of additional borings and laboratory testing as discussed in response to Question 10. -i ~ 1 ] Q.12. What is the NRC Staff response to Item 4 in Stamiris' supplement to contention 27 i A. The matters of grouting gaps prior to cutting duct banks and breaking up the mudmat were considered at a meeting between CPC,
- /3 Bechtel and Bechtel's consultants as reflected in " Meeting Notes
< N, v.. 'r No. 882." (Attachment 3) These notes at page 3, paragraph 6 <f " p) k (. " state: The duct banks which appear to be restraining the building firt settlement should be isolated from the building as necessary. The' building construction should continue, thereby providing more weight on the foundations. Any gaps between the footing and the mudmat would require grouting. The grouting would not be necessary prior to preload. It was pointed out that i from a safety and a butlaing distress point of view, it would be advisable to grout existing gaps prior to releasing duct banks. It was also suggested that the mudmat be broken up prior to preload. I Similarly, in the trip report by CPC (Attachment S) for this same ~l '1 November 7,1978, meeting, the following account of the above 1 discussion is given at page 3: I l i I l 1't i- ^ h
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[ l . 17 - q i The question of grouting the gaps between the footing NS N j. and the soil was discussed. Dr. Peck and Dr. Hendron I33
- i did not feel the groutiqg of the gap between the foot-ing ard soil was necessary prior to preload. However,
~ 3 discussion continued and it was concluded that Bechtel ~ "j would grout any gaps between the footing and soil after 4 the preload'had been removed. It was suggested by the 4 consultar.ts that the mudmat be broken up prior to pre- ".i load application and that early grouting may also be l beneficial in relieving some building stress. 3 \\ j 'Jith respect to the condensate lines, the Staff was advised j by 50.55(e) Interim Report #4 to Management Corrective Action h Report 24 dated February 16, 1979, and forwarded by cover letter ~ dated February 23, 1979, of the preloading progress and that the o.,. M )k' two condensate lines had been cut. Interim Report #4, at page 5, %, t' MO p.* stated: y Y" 2. Preload Operation Preloading of the Diesel Generator Building is continuing. As of February 2,1979, the granular fill material for the preload has been placed to the elevations shown in Figure 4]. 3. Cutting of the Condensate Pipelines s The two 20-inch condensate lines and two 6-inch condensate d lines shown in Figures 9 and 10 have been cut outside the ' turbine building all to prevent potential overstressing of the pipes during preload. Continued surveillance will i be prosided on the cut pipelines and further evaluation will be provided in subsequent reports." ~' The Staff is unable to conclude that grouting the gaps prior - ) to isolating the duct banks would have been the better approach to preloading. There are advantages and disadvantages associated with either decision--to grout or not to grout. The decision not to grout likely allowed some immediate stress relief in bay areas 3 4 4 \\ L .+ -
Tz l... 1 1 ^ fgusuY tUs & j W { and 4 when the duct banks were released. On the other hand, it is/ i 5 uncertain as to the extent that beneffetal reduction in additional stresses to other portions of the Diesfl Generator Building would I have resulted had grouting been performed prior to cutting away the i j duct bank. i [. With the benefit of hindsight, it would appear that initially k s not grouting and a more gradual lowering of the structure after 6 i l (h release from the duct banks would have been preferable, rather than [ s I the actual abrupt release of the structure. Such an approach would o 4 have permitted a more gradual redistribution of loading to the gE( 6%<. m Die 1 Generator Building's foundation. Grouting then might still ,4 N have been necessary following the initial. relief of stresses in order to result in more unifonn future settlement and to avoid the inducement of possible additional stresses in other portions of the 3 DieskiGeneratorBuilding, bML,c 4 i It is the Staff's understanding that the condensate lines were j actually cut. Therefore, these unconnected lines were apparently s 4 not a cause of additional stresses to the Diesel Generator Building, i With regard to not breaking up the mudmat.beneath the Diesel I j Generator Building, it is likely this decision lessened the stresses imposed during surcharging since the structure foundation was stiffs r and better able to span any soft soil areas that may have existed. 1 l There is a trade off, however, in that not breaking up the mudmat I
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= 1 -(. 4 9, :l t 1 ' reduced the effectiveness of the surcharge in consolidating the softer foundation soils which were being bridged by the structures \\ l' foundation and mudmet. If in the future during plant operation, 4 g 0 new or extended cracking of the wall footings and mudmat were to p occur, redistribution of loading pressures could result and possibly d1 lead to additional settlement. d The Staff therefore concludes that CPC's failure to act listed in Item 4 did not adversely effect resolution of the soil settlement issues. L Q.13. What is the NRC Staff response to Item 5 in Stamf ris' supplement to Contention 2? A. -This Contention is essentially the same as Stamiris Con-tantion 2(d) addressed in response to Qu'estion 7 of this testimony. ( ~In summary, CPC's decision to continue construction of the Diesel l h Generator Building does make it more difficult and costly to select thel removal and replacement option, but it does not eliminate this ], option. The Staff views this decision by CPC as evidence of its ] willingness to proceed at its own risk; it does not view CPC's decision as having an adverse effect on resolution of the soil ] settlement problem. } l -What is the NRC staff response to Item 6 in Stamiris' supplement ] i Q.14. r$g to Contention 27 i f I l-1. .t
,__ ~ : - z =- t.... ] + t' [I -t 1 - 20'- 1 l [ A. ' Had the FSAR been tendered as late as August 1978 instead L;- of August 1977, little or no detection of inconsistencies would ~ti have occurred during this interval with respect to soil settlement problems. The basis for this position is the following statement <.[ by the Applicant in response to 50.54(f) Request 1, page 1-3 of 9 " Responses to MRC Requests Regarding Plant Fill," Volume 1: N Through the above procedures and actions, the FSAR and f project design documents are constantly being reviewed / j and compared against each other. When inconsistencies . are identified, they are corrected. However, there are .3o some sectlons of the FSAR that are essentially inactive + (e.g., the FSAR section relates to items for which the design, procurement, and construction phases have been completed and there have been no recent document changes or NRC questions to prompt a review of the.section). Prior to the identification and investigation of the Diesel Generator Building settlement starting in August 1978 FSAR Section 2.5 and Subsection 3.8.5 (which were the areas of contradictions in the PSAR.and FSAR as described by I&E during the meetings of February 23 and March 5,1979) were considered inactive. All of the major plant backffll operations were completed, no sig-i i nificant revisions to the related civil specifications ~ or calculations were made, and only two NRC questions were received at that time. These two NRC questions were related to Section 2.5 and dealt with the seis-l micity of the Michigan region. l t .+ Q.15. What is the NRC Staff response to Items 7, 9 and 11 of Stamiris' supplement to Contention 27 1 Q . l A. The Staff is uncertain as to the meaning of " reconstruct geometry of area" in the beginning of Item 7 and therefore the Staff cannot respond to this aspect of the Contention. The Staff views 1 i t l.2
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. s, 1 4. R } the intent of supplemental Itas 7, 9, and 11 of Stamiris Conten-f tion 2 as questions en the adequacy and conservativeness of the .] selected preloading solution to reedy the plant fill settlement probl e of the Diesel Generator Building. The Staff recognizes that decisions and actions by CPC are naturally affected by cost 1 and schedule considerations. The Staff does not feel tha t these competing concerns are irreconcilable, but rather the Staff attempts ] to recognize the needs of applicants while exercising its regulatory responsibility through firmly insisting upon acceptable margins of safety and assurances that provide for protection of the health and safety of the public. The Staff therefore concludes that the A examples listed in Items 7, 9 and 11 have' not adversely affected resolution of the soil settlement issue. Further, with respect to supplemental Item 11 which claims that the depth and breadth of surcharge was limited by practical consideration of the Diesel Generator Building and Turbine Building .h6 and that this afforded less than optimum conditions for surcharge, \\ \\v'g the Staff believes the significant issue here should be, not n D* whether optimum conditions existed, but whether accep results were -hieved by the surcharge program as executed. In this regard, j the results of additional borings and laboratory testing requested
- .]
by the Staff and the Corps are to be provided for review in the '.1l near future. The assessment of these results oy the Staff and the t ,{ Corps will be the subject of later testimony in this hearing. L; , 1, - M ~ ..l = - -. .= .=
c - - u = _ - - [- a i i Q. 16. What is the NRC Staff resr.ae to Item 8 in Stamf ris' 1 supplement to Contention 27 A. In February 1978 the NRC in its review of the Midland FSAll forwarded Request 362.2 which sought documentation of the ;nethod CPC l used to remove the loose natural sands (sands with less than 75% relative density) from the foundations of safety related structures as CPC committed to do in the PSAR. In subsequent submittals in response to NRC Request 362.2, CPC provided the results of boring / t explorations which had been drilled in August and September of 1978 and additional explorations in 1979. The date when these borings were drilled occur after the site area fill had been placed. These late results and evaluation bf the boring information which CPC has documented did not indicate the presence of loose natural sands i beneath safety related structures. Based on these facts, the Staff 1 is unable to conclude that CPC failed to excavate loose natural sands as committed to in the PSAR or that this failure contributed i i to the inadequacy of the subsoils. l Q.17. What is the NRC Staff response to Item 10 in Stamiris' supplement ( to Contention 2? t A. The resolution of the " Seismic Deferral Motion" was achieved consistent with the NRC Staff's needs as expressed at the prehearing conference of April 27, 1981. No compromise of applicable health and I safety regulations is associated with this resolution. I 1 I r 4 -. _. - ~,... -.. .. ~
y -._.__m_.s_- c : -- - l..l. j l' .l i 4 Q.18. What is the NRC Staff response to Item 12 in Stamiris' supplement
- i, to Contention 27 A.
Ms. Stamiris is correct that these manifestations of the j breakdown in quality assurance existed prior to December 6,1979. ~I Such matters were the subject of the NRC Staff Motion for. Summary l l l Disposition on the Issue of Quality Assurance Implementation Prior q a ( to December 6,1979. However, as other Staff testimony demon- -nM 4j strates, the quality assurance program now satisfies all required NRC criteria; further, as a result of revisions in the quality i assurance program, the improved implementation of the program, and 1 other factors discussed in testimony submitted by James G. Keppler, l the NRC now has reasonable assurance that quality assurance and quality control programs will be appropriately implemented with i respect to future soils construction activities including remedial actions taken as a result of inadequate soil placement. E ci ,1 L i l 1 i ~ EE22121_EE____ _ __E_'i_i_E_T_~I_'_E_~__ET_~"~ ~ E' " ' ~ ' ~ ~ ' ~~
v {,.. ,l, - p.- 1 Attachment I d:'. e DARL S. H000 0FFICE OF NUCLEAR REACTOR REGULATION U.S. MUCLEAR REGULATORY COMMISSIO'i ~ PROFESSIONAL QUALIFICATIONS I am-a Senior Project Manager in the Division of Licensing Office of Nuclear Reactor Regulation. I am responsible for nanaging licensing activities by the Comission with respect to Midland Plant, Units 1 and
- 2. -
I have served in the position of Project Manager with the Comission since August 1976. This position provides for the nanaging of radiological safety reviews of applications for licenses and authorization to construct or operate light water nuclear power plants. As of April 1980, the position also provides for the nanaging of the environmental reviews of such applications. I assaned responsibility for Midland Plant, Units 1 and 2, when the application for operating licenses was tendered in August 1977. Other nuclear plants for which I have previously served in this capacity are the standardization design of Westinghouse which is designated RESAR-414 (Docket STN50-572), Catawaba Nuclear Station, Units 1 and 2 (Dockets 50-413 and 50-414), and River ( Bend Station, Units 1 and 2 (Dockets 50-458 and 50-459). Between June 1969 and August 1976 I held two sequential positions within the Nuclear Power Systems Division of Combustion Engineering. Inc. (C-E) at Windsor, Connecticut. After liarch,1973, I was Assistant Project fianager for the Duke Power Project. This position provided assistance in directing all efforts by C-E to design, fabricate, purchase and license the nuclear steam supply systens, reactor core, and i associated auxiliary systems for Cherokee Units 1, 2 & 3 and Thomas L. Perkins Units 1, 2 & 3. The position assured that all aspects of the contracts were met and that safe and reliable systens were provided to the required schedule and at a reasonable profit to C-E. I assisted Duke + Power in preparing the Preliminary Safety Analysis Report (PSAR) and provided for all C-E licensing support for these units.
- I also provided coordination of all other nuclear plants referencing the C-E Standard Safety Analysis Report to assure compatibility with C-E standard reference design. Until March,1973. I was a Project Engineer in C-E's j
Safety and Licensing Departnant and was responsible for licensing of 'l nuclear power plants. I coordinated the preparation of the tiilistone 1 Unit 2 PSAR and FSAR and the Calvert Cliffs Units 1 & 2 FSAR and d interfaced with NRC, the utility, architect engineer and all C-E q functional departments on licensing support matters. I ensured that NRC criteria, standards, and guides were incorporated into the nuclear steam
- ]
supply system design. D C i A
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J. .l - ~. .c l,. -2 .(. Setween August 1966 and June 1969. I was a Nuclear Safety and Radiation - Analysis Engineer in the Nuclear Safety Unit, Nuclear Division of the 1 Martin Marietta Corporation at Saltimore, Maryland. The purpose 'of this t[_ position was to perfom hazard evaluations for nuclear power sources -i applied in space missions. My primary duty was to detemine public { exposure to radiation for malfunctions occurring during the intended i mission. I also detemined means by which the hazard potential for a nuclear space systems could be mitigated to the extent that nuclear j safety criteria were met. ~ I conducted research with regards to the development of suitable criteria for permissable exposure levels and their probabilities, taking into account the dependence of acceptable a i risk on the benefit to be derived. My primar SNAP 29 (Systems for Nuclear Auxiliary Power)y assignment was with the project. - My evaluations of this nuclear power source included the formulation and application of .;j computerized models for the transport of fuel released at high altitudes, i in deep ocean and in shallow waters. I derived models for these release [ areas to incorporate the activity into human food chains and determined the expected ingestion dose, the number of people involved and the exposure probabilities. Inhalation dose was determined for radioactive 1 fallout from the high-altitude release. Cetween February 1965 and August 196G I was a Nuclear Quality Control. Engineer within the Electric Boat Division of General Dynamics at Groton, Connecticut. The purpose of this position was to provide control of quality for naval reactor systems, components, and shielding during the ( construction or overhaul of submarines by this shipyard. My primary area of responsibility was shielding. Duties included establishing procedures for the inspection of fabrication and installation of lead and i, polyethylene shielding, and resolving problems in complying with these or other shielding procedures. The position required a knowledge of nuclear t theory, S5W systens design, Bureau of Ships contract and design i requirements, non-destructive testing techniques, and quality control requirements. 8etween November 1963 and February 1965 I was an Aeronautical Engineer 1. for Nuclear Propulsion and Power at the George C. Marshall Space Fli Center, National Aeronautics and Space Administration in Huntsville ght 1 Alabama. I perfomed investigations of the nature and nagnitude of the q; nuclear radiation environment, shielding systems and safety systems associated with proposed nuclear space vehicles for candidate space p missions. Between November 1963 and college graduation in 1962. I held various ~ y positions including chief of a missile electronics training unit at Redstone Arsenal, Alabama; student at the U.S. Army Signal Officer's Orientation Course at Fort Gordon, Georgia; and Marine Engineer for ordinance and special weapons within the Design Division of the Norfolk Naval Shipyard, Portsmouth, Virginia. ! i . h a. l i 1 J. ,-u., m %=.g+-~en.--e- = =whe**-
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I received a Bachelor of Science Degree in Nuclear Engineering from North Carolina State University in 1962. I an a member of the Health Physics j - Society. O u 9 I 9 i ~ ; i l . 6 l l C e i ' 4 l .i n. li 6 iI l,: l1 1 t i
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_ _ _.m,_ . ?.. C PROFESSIONAL QUALIFICATIONS AND EXPERIENCE .i]'. !!25.: . Joseph 0. Kane 1 ADDRESS: 7421 Miller Fall Road Derwood, MD 20855 h' EDUCATION: B.S. Civil Engineering 1961 Villanova University ..a l M.S. Civil Engineering 1973 .j Villanova University 1 Post-degree studies. Soils and Foundation Engineering ( University of California 1972 j. University of Maryland 1978 l .j PROFESSIONAL REGISTRATION: Registered Professional Engineer (1966) - Pennsylvania 12032E PROFESSIONAL SOCIETY: C a arican Society of Civii Ea9 neers 4 l, EMPLOYMENT POSITIONS: j February 1980 - Present Principal Geotechnical Engineer U.S. Nuclear Regulatory Comission 2 l "l May 1977 - February 1980 Geotechnical Engineer U.S. Nuclear Regulatory Comission d October la75 - May 1977 Soils Engineer U.S. Nuclear Regulatory Comission ~J 4 e August 1973 - October 1975 Supervisory Civil Engineer Chief. Soils Design Section i: U.S. Army Corps of Engineers Philadelphia District January 1963 - August 1973 Civil Engineer Soils Design Section J U.S. Army Corps of Engineers i Philadelphia District January 1962 - January 1963 Design $ngineer McCormick - Taylor Associates { Philadelphia, Pa. .O esge ea yg g .=~~+ -..,m ,.#.~
_ a.c _ i -u: 1,, ,p. 3 Professional Qualificatic.s and Experience s Joseph D. Kane D 9 PROFESSIONAL EXPERIENCE
SUMMARY
d 1975 tc Present In NRC Division of Engineering, Geotechnical Engineering d' Section, Mr. Kane has specialized in soil mechanics and i foundation engineering. Experiences in this position 1 4 have included the following: H 'i a. Evaluation of the foundation adequacy of proposed i sites for nuclear facilities with respect to design ) and operational safety. This work has included t evaluation of geotechnical, sofis and rock mechanics, 1 foundation and earthquake engineering related aspects. )j The results of this review effort are sununarized in a safety evaluation report for each of the proposed j facilities which have included nuclear power plants, y nuclear fuel reprocessing plants and uranium mill tailings waste systems. b. Serving as a technical adviser for soil and foundation engineering related aspects in the development of regulatory guides, acceptance and perfonnance criteria ( that are intended to assure construction and operational scfety of nuclear facilities. c. Serving as a technical representative for the Office of Nuclear Reactor Regulation on the NRC Advisory Group concarned with federal dam safety. j d. Serving as an instructor for the Office of State Programs in the training of state personnel who 4 1 are responsible for construction and operational inspections of uranium mill tailings embankment retention systems. 1963 to 1975 During this period Mr. Kane was employed with the U.S. }4 Army Corps of Engineers, Philadelphia District and attained the position, Chief, Soils Design Section, Foundations and Materfats Branch, in 1973. Professional experiences with the Corps of Engineers have included J the following: 'I a. The embankment and foundation design of four large i multi-purpose earth and rockfill dams with appurtenant
- j structures (spillways, inlet and outlet structures, control towers, flood protection facilities, etc.).
] Responsibilities ranged from the initial planning of 4 4
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_. _ = __ }.s. .I' f Professional Qualifications - and Experience ,.j' (. Joseph D. Kane 1 subsurface investigations to select the most J feasible sites through all design stages which 1 were culminated in the final preparation of J. construction plans and specifications. This work included planning and evaluation of laboratory ~ testing programs, studies on slope stability. seepage control and dewater'ing systems, settlement, bearing capacity, liquefaction 3 embankment safety ,j instrumentation and slope protection. a b. Served as a technical consultant to field offices charged with construction inspections for assuring completion of structures in compliance with design analysis and contract specifications. Participated .j in the development of needed modifications during i construction whenever significant changed site conditions were uncovered. i c. Directed the efforts of engineers in the Soils Design Section in other fields of civil work projects that included the embankment and foundation design of ~ levees, waterfront pile supported structures and -b disposal basins for the retention of hydraulic dredge waste. l 1962 to 1963 Served as design and project engineer for private i t consulting finn. This work included the design of large federally funded highways, a race track and various structures constructed to provide a Pennsylvania f State park marina. i l . i j q ']' Li a i 1 I O i 1 I [1 =
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^ =- ~ _. - > < j Frank Rinaldi, P.E. Structural Engineering Branch
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Diviston of Engineering j Office,of Nuclear Reactor Regulation /
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/ j U.S. Nuclear Regulation Comission j/ ? / My name is Frank Rinaldi. I presently reside at 5506 Beech Ridge Drive, Fairfax, Virginf a, 22030 and I am employed as a Senior Structural Engineer ] in the Structural Engineering Branch, Division of, Engineering Office of i Nuclear Reactor Regulation, Washington, D.C., 20555. / Professional Qualificattons .) I received a B.S. degree in Civil E'ngineering! rom the City College of .i f New York (1966) and a M.S. degree in\\ Civil ngineering from flaryland
- 2. i University (1974).
\\ .I I am a registered Professional Enginee\\ l the Comonwealth of Virginia (1972). I am a member of the Main Committee of jhe ACI-ASME Committee on Concrete Pressure Components for Nuclear Service (Concrete Reactor Vessels and Conta f nments). \\ I have been employed by the HRC, Structural ' ngineering Branch since 1974 E as a Senior Structural Engineer. My duties include development of design criteria for nuclear structures and participation in the formulation of j safety criteria. Duties also involve safety-related review of structural i and setsmic design criteria (Safety Analysis Report & Topical Reports) for power systems and the evaluation of nuclear conta'inment structures, reactor vessels and other structures and components. / The following is a sumary of my previous profession 1 experience: 1971-1974 U.S. Atomic Energy Commission Fuel, Fabrication and Transportation anch i (Structural Engineer) .i /
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Oevelopment and Testing and Evaluation (General Engineer). 1970-1971 Naval Facilities Engineering Command-Division of search 1968-1971 Naval F ilities Engineering Command-Electronics Fa lities {} / Support Branch (Structural Engineer). \\ l 1966-1968 Naval Facilities Engineering Command-Chesapeake Division 4 j (Civil Engineer).
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Tl, =. - I 'D EUGENE J. GALLAGHER 0FFICE OF INSPECTION AND ENFORCEMENT [. U.S. NUCLEAR REGULATORY COMMISSION ~ 3- ' PROFESSIONAL QUALIFICATI0MS ( I am a Civil Engineer in the Division of Resident and Regional Reactor i-Inspection, Reactor Engineering Sranch Office of Inspection and j,. Enforcement. J 't I received a Bachelor of Engineering Degree in Civil Engineering from i Villanova University in 1973 and a Master of Science Degree in Civil / Structural Engineering from Polytechnical Institute of New York i in 1974. I am a registered Professional Engineer in the States of Illinois (#37328) Florida (#29114) and Louisiana (f16376). I am a member of the American Society of Civil Engineers, American Concrete Institute and i Tau Beta Pi National Engineering Honor Society. In my present work at the NRC, I provide technical assistance in the area of civil engineering to Regional offices and resident inspectors with t particular enphasis on the design and construction of reinforced and prestressed concrete structures, foundations, structural steel buildings and in structural testing and surveillance. In addition. I provide C technical input for the development and interpretation of industry codes, standards and regulatory requirements relating to inspection activities. From 1973 to 1981'I was a member of the NRC Region 3 inspection staff responsible for the inspections of civil engineering aspects of plants j under construction and in operation. This included the Inspection of laboratory and field testing of concrete, steel and soils materials, earth embankments and dams, material sources, piping systems and reinforced and prestressed concrete structures. In addition, a raview of management controls and quality assurance programs were performed at "{ plants under construction. I participated in approximately 90 inspections of reactor facilities. t h Prior to joining the NRC Staff I was employed by EBASCO Services, Inc. in p New York City from 1973 to 1978. I performed designs of reinforced goncrete and steel structures, design of hydraulic and water supply 1' systems and preparation of specifications for construction. From 1976 to 1978 I was the civil resident engineer at the Waterford 3 Nuclear Plant il I site responsible for providing technical assistance to construction. 't 'l During 1972 and 1973 I was employed by Valley Forge Laboratory in Devon, PA performing inspection and testing on concrete, steel and soil materials. J a 1
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s A00!TIONAL NRC TRAINING Funhmentals of, Inspection, NRC, February 1973 (40 hours) BWR Fundamentals Course, NRC, March 1973 (40 hours) hours) ' 1978(80, Concrete Technology and todes, Portland Cement Assoc., May 4 Quality Assurance Course. NRC, August 1973 (40 hours) Nondestructive F.xamination and Codes Rockwell Int'l., August 1978 (120 hours) PWR Fundamentals Course. MRC, November 1973 (40 hours) Welding Metallurgy, Ohio State University, September 1980 (80 hours) i t e J o t l i l a "1 1 '4 1 e t 1L 4 i 1 ~ _e--w- ... ~......... ,w.
4.. .s- .g y ll 3 ' lg
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il A: -[.__ j rp-Foute W 1his Capr for File 16.3.4 & 16.3.6 ) f t-lay Issue Da*.e November 22. 1977 r. Project Midland 1 4, 2 I on n CIluGER Mwsr File D tle NCR's on Becheel j' g Construction and num14ev cmeent pJ., Report h 0T-203
- ,, n 21s Nonconfo2EaEle'eTrNrt is Issued 2:
Prepared WNJA S.w Date O- ? A ~7 A Anad By,VWd& Date #'/* 1/e - i C. L. Richardson s e Bechtel Lead QAE Written Reply Requet,te4,,3r Date 12/16j. .1 - Cw#ve Action Requested 3r Date 12/30/~ who is reroonsible for corrective action. " ' 'l
- 5!
Nonconfermance Desc=iption and Supporting Details: ,1 'I See attachment. l i 1 i b Yes O No E See Procedure 9 (For Nuclear Trojects only) ~ ~ ~ - - - - AEC Reportable -D" Stop Wdrk Necessary Yes C No See Procedure 16 - Stop Werk No v i No Hold Tags Applied ( Recemended Corrective Action: See attachment. I e 1 .' } Corrective Action Takan: d See attachment. r.1 4 IVerification of Corrective Action Required Yes @ No 0 1Method of Verification: Reviewed letters GLR-12-77-517, GLR-1-78-001 and GLR-01-78-040 from G. L. Richardso-i to J. L. Corley; letters 216FQA77 and 6TQA78 from J. L. Corley to G. L. Richardson; letters 0-1621 and 0-1651 from J. Newgen to C. Richardson; Bechtel QC Training I, Session QCTM-4250; and NCR's 10$$ and 1094. Uonconfo mar.ce closure Confined By -*vh
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[ I Date 0-1-W 1 d To be completed at time of closure by Consumers Power QA Services. j. Page 1 of 4 ) J
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== { I 16.3.4 & 16.3.6 Icaue Data Novemb r 22, 1977 l Project liidland 1 & 2 File Title NCR'.s on Bechtel , g Construction and Quality Control - =- Q Attachment to NCR No QT-203 i Nonconformance Description and Supporting Details: Project Quality Control Instruction R-1.00, " Material Receiving Instruction" Section 5.2 of Revision 3 and Section 5.1 of Revision 5 states in part, " Require-ments for the sampling and testing and the acceptance criteria reference documents. shall be noted on the applicable IR" and Section 5.4 of Revision 3 and 5.3 of Revi- .A sion 5 states, " Review any required user's test data reports to verify that they M have been satisfactorily completed". .m Part A 1 QCIR No. R-1.00-1560 for Zone 4A Fine Backfill references User's Test Report No. 1 1 0630 and the acceptance criteria as: I q Steve Size % Passing 4 i 1" 100 3/4" 90-100 1/2" 75-90 In 3/8" 60-85 !F
- 200 7-15 lj Contrary to the above, User's Test Report No. 0630 references 75-100% passing as i
the acceptance criteria for the 1/2" sieve, consequently 94% passed the 1/2" sieve f. and it was accepted when actually it failed. j Part: 3 i l QCIR No. R-1.00-2105 for Zone 4A Fine Backfill references User's Test Report No. 1036 and the acceptance criteria as: Steve Size % Passing f 2 1" 100 3/4" 90-100 1/2" 75-90 3/8" 60-85
- 200 7-15 Contrary to the above, User's Test Report No.1036 indicated 81% passing the 1/2"
,j sieve and accepted, this should have indicated 91% passing the 1/2" sieve and failed. 1 i<
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Page 2 of 4 I Mwhm-m c e ---- ._.-m.s..% . - _ _,_., _._--.__._,-,rm- ._.++=>-_,.-+,_-,w w mw q- -e--. + m ee--ee. - nee e --e.ne-.**em .r N e.+-* umoress-e ^
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16.3.4 & 16.3.6 l," * / * - Iccue Data Navenbar 22, 1977 l !. Project Midland 1 & 2 ' j_ File Title NCR's on Bechtel M 4==nr Construction and Quality Control ~ t't Attachment to NCR No QF-203 f yi O Nonconformance Description and Supporting Details: (Contd) f Part C ) i jT QCIR No. R-1.00-1836 for Zone 4A Pine Backfill references User's Test Report No. (l 0836 and the acceptance criteria as: i Sieve Size % Passina 1 1" 100 l 3/4" 90-100 1/2" 75-90 3/8" '. 60 4 1
- 200 2-20 D l.
Contrary to the above, User's Test Report No. 0836 hgl% passing the f 200 sieve i and it was accepted. l Reconnnended Corrective Action: U ~ =- Part A & 8 1. Present these findings to Bechtel Project Engineering so Project Engineering can determine what additional tests, reviews, etc. are needed to justify the material these tests represent. Have Project Engineering determine the accept-I ability of the material these failing tests represent. 2. Determine the underlying cause(s) for these discrepancies and take corrective action to preclude repetition in other areas. .j. Part C .i rj 1. An evaluation of this material is not needed because the acceptance criteria 'g as given on QCIR No. R-1.00-1836 was 12-20% passing the No. 200 sieve. It should have been 7-20%, therefore, the test result of 11% is passing. l 2. Determine the underlying cause(s) for QC not rejecting the Zone 4A Fine Back-fill per the QCIR No. R-1.00-1836 acceptance criteria of 12-20% passing the ,l No. 200 sieve. Review the interface between the material receiving QCE's and 1 the test lab QCE's to determine if there is a breakdown in comunicating the i inspection criteria for materials being received. Take corrective action to preclude repetition. l . EE: tt ] :.=:.=~ 1 =- f. 1 Page 3 of 4 ( --
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g Filo g it.J.0 6 19.J.e ../ Iceve vato November 22, 1977 ! t [25:;. Eile Title NCR's on Bechtel Project Midland 1 & 2 Construction and Quality Control l.-.--. i Attachment to NCR No QF-203 t e s' I j Corrective Action Taken: a Part A & B l 'i 1. NCR-1094 was written to identify the nonconforming material in Part A. Project j Engineering dispositioned this meterial "Use-As-Is". NCR-1055 was written to lj identify the nonconforring matarial in Part B. Field Engineering has disposi-l ~ j tioned this material " Reject For Q-Use". This material was only used in Non-Q Areas. 2. N d -'~4"e cause 'o f eb-- ::d'-':-- >== improper review of the test r=~ee .] by Quality Control. To prevent this condition from recurring, a training session j was held wJ cn cognizant individuals in attendance. Part C t; i 1. Based on response given in Part A of letter 0-1621 from J. Newgen to G. Richardson, it was necessary for Field Engineering to justify the more stringent requirements and the use of this material when it did not meet these requirements. The j *L*; justification was given by Field Engineering. .l t-2. The underlying cause of this condition was that the Civil QC Engineer identified the different gradation requirements on the QCIR and failed to bring it to the attention of the QC Receiving Engineer. To preclude repetition, the cognizant QC engineers in both disciplines were reminded that close interfacing is a necessity. i 4
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1.:.; o g- { CONSUMER 3 powg2 COMPAW Bechtel Power Corporation J. 0 EDE01E} Poet Offlee aos 214T -1 FE81 578 J m, %. / j. FIED QUAUTY ASSURANCE i. MIDLAND, MICHIGAN January 31,1978 );
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-q.s., Consumers Power Company P. O. Box 1963 .. gd l Midland, MI 48640 C# Attention: J. L. Corley ca. T Job 7220 Midland Project j CPCo NCR QF-203 Final yttf. GLR-01-78-040 t I j
Dear Mr. Corley:
Ref:
- 1) Letter J. Corley to G. Richardson, 216FQA77, dated 12/23/77 The following is in response to the above subject nonconformance i%
report which identified problems on user tests for backfill material. 'E For the material identified in Part A of the subject finding, NCR-1094 was written. This NCR has been dispositioned by Project Engineering ( as Use-As-Is, and is now closed. For the material identified in Part 8 of the subject finding, NCR-1055 was written. This NCR is closed as previously addressed in letter GLR-01 001. For the material identified in Part C of the subject finding the field I j has provided justification as to why FMRs had stricter requirements than l those given by Project Engineering. In letter 4 ',Z, dated 1/17/78, l Field Engineering stated in part: 0-/gSty,g.gg l The reason for specifying a 12-20% range of aggregate passing through a f200 sieve, when Specification C-210 Rev. 5 and Dwg. C-130. Rev. 6 allowed a range of 7-20%, was strictly for commercial reasons. The vendor said he had a supply of "12-20% material". When this material actually turned out to be 115, it j was still acceptable for use in accordance with our specification and drawing. This concludes our action on the subject nonconformance report. Should you desire additional information, do not hesitate to bring it to my i..rs. attention. ! t...... ! T33 Very truly yours. 2.x. RL4=s2 G. L. Richardson LEAD QUALITY ASSURANCE ENGINEER GLR /JGH/sw ++a++e4*-r*. .e go..s
{..- . ~. ~~ ~ gy 3 .a q l "B Sechtel PowerCorpcration au.sr Intercffice Mememnddm ..4 !. G. L. Richardson j Jcb 7220 liidland Project January 17, 1973 em J F:P. ?raparation 0-1551 J. F. i'awgen ,,3., Cons truction
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j , m..!" liidland,I,t, l e.,,,, .. g 2 J a. F.cferencas: 1) Ltr. Richardson to ilewgen, GLR-12 77'-532, dated 12-23-77 (I 8840) Ij
- 2). Ltr. Corley to Richardson, 215FQA77, datad 12-23-77,
~ ~ 1 This memo is in response to referenca 1 and is nu bared sis:tilarly. 1. Our reason for specifying a 12-205 range of aggregat< passing thrcu a nus.bar 200 s,ieva, when Specificatica C-210, Rev. 5 alle:ind q i-en:;gh s of 7-20.5, was strictly for cc=arcia.1 reasons. The vendor. Said he had I a supply of "12-203 material". !! hen this material actually turned cut 7) to be 115,. it was still acceptable for use in accordanca with cur t
- 3 pact fication. Tha only. " error" was in dispositioning I!CP QF-203 by
. ravising the iT?., rather than noting to "use as is". 2. The'intant of cur previcus response to blank signatura bloch en F.B's 1 CY-3171,.% v's 1 ?. 2,vtas to pe Q t out the fc11cwing: y j .n. F.cvisiens 'to FMR's for cc:.wrcial purposes de not fr.11 1 und s the QA program. t ct b. Paragraph 3.10.2 of the IJI-1, Rev.1 limits the' nacassity ~ij cf the approval procass of F?.? revis. ions to those uhich t. ad:frass spcificatica changes. Ccmere!al chaliges to F;iR's are not governed by F7G-3.CCO. ~ c. p e j '1 t. + = - ) e== . m t== i .l adp WPeseaw..%, % e.we eg,me wn. mee m me. --=..h s e r + = g e,,r-em g,. m w e w w w.e.e,.mgy, m me -e a. merg p.emee. em s, ---we e,ww -am e ,49
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_ _ z-4.. /. 3 c) G g Preparation Bedrital PowerCorporation Fi s.:.,1 0 R.:ts 2
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N EiiiF ~ + '] 3. Na disagree that a censric proble: currently exists in the appraal a cca@l(steness of Fi!R's. The PFE and A.cFE's have indicated the ir.::linacy j of signat'ure c:nissica is noglegible on "Q" F!IR's. Thosa which h. n .j lacked signatures were returned when disccvered. y f 4. The FFE and APFE's have intensified their survdillanca of "Q" It.1's L'i to 0.ssure the requirr.ents of FPG-8.000 are i=ple.aented. ,.I. .1 s 's 7'.,.%. /,.4 .I ,. j.,s... 3 o
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= u .: e Bhchtel Associates Professional Corporation i _lj - 777 East Eisenhower Par <way """ k# M' N p q, i.
==as P.O. Des 1000, Ann A'est. Mahgan 491C{ MEETING NOTES NO.,882 j MIDLAND PLANT UNITS 1 & 2 i . CONSUMERS POWER COMPANY j A {' BECHTEL JOB 7220 DATE: Tuesday, November 7, l'978 i,, PIACE: Champaign, Illinois i 3
SUBJECT:
Settlement of the Midland Diesel Generator Building j-FILE: 0279, C-280, C-2640, C-2645 i ATTENDEES: CONSULTANTS CPCo BECHTEL J , J. Dunnicliff T.C. Cooke S. Afifi Dr. A. Hendron, Jr. C.A. Hunt
- 4. Betts Dr. R. Peck D.E. Horn S. Blue R.M. Wheeler W.R. Ferris D.E. Sibbald Y.K. Lim A. Marshall P.A. Hardines B.C. McConnel N.O. Rothwell j
N.W. Svanberg d PURPOSE: To obtain formal recoemendations from the consultants. 1 ITEMS DISCUSSED: 1. Background Information Bechtel presented sectiement data for the diesel generator building. il The data indicated no si nificant change in the previous trends C ] except for the eastern most diesel generator pedestal which expe'rienced l significant additional settlements during the past sanch of (approx-imately 1 inch at the N-W corner, 3/4 inch at the X-E corner and 0.4 i'nches at the other two corners). It was noted that the soil cust pit was dug in etnia bay and seen of the diffurential settlesent i could be attributed to the pit. The remaining boring data was consistent with previous boring information. The possible corrective actions previously discussed were reiterated: a. No corrective action taken except grouting under foetings. b. Modify the present strip fuundations for the valls to a .j continuous mat foundation for the, entire building. I 'N g._
~_m _ m. _ _. _ a__._ . m.o.~...~.. 1 P g3 2 1-f c. Prelcad and consolidate the soil under the building. y d. A combination of Icess b and e above. Underpin the building to transmit loads directly to the undis-s. turbed soil layer. j f. Remove and replace fill. 2. Recommentations Soil boring data substantiated the jobsite observations by Dr. Peck i that the fill is settling under its own weight. There are only two suitable options to correct the situation: 1 a. Remove fill and replace with denser material. ,b. Densify ext, sting material in place. d-Ther'efore, the preload option is suggested to consolidate the { material in place. The soil data' indicate a nonhomogenous fill. Therefore exact amo.mt of preload and the consolidation duration i cannot be estimated from the laboratory tests, To predict the amount and duration of the preload, instrumentation of the soil movement is needed. 6 mo f,Q I i It was indicated that a 5-month period is available in the schedule %b*9 for preloading. Dr. Pack stated that it is likely\\that the settlement g,* will occur rapidly once the preload is placed, but that the additional settlement could not be predicted with any accuracy at this time. 1 A range of 6 to 18 inches was considered to be quite pessimistic. Dr. Peck recommended proceeding with the insturmentation and preload as rapidly as possible. 3. Other Options The other options were briefly discussed. Options a and b would not stop the differential settlement and there would still be C ij settlement of the underground utilities. The effects of the settlement may show up after several years, causing problems during plant ope ration. Underpinning (Option e) would only be necesnery in case of structural distress after the preload had been comp 1sted. a Underpinning prior to p*ticad would not help the settlement of the q soil under its own weight. It was not felt to be an adequate q solution. 4. ' Pond Fill 9 i The consult mts suCuested that the best sequence would be to place UCd DN the preload and then raise quickly the cooling pond water level to Tebca$ its operating level. This sequence would allow the consolidation N,W to occur as rapidly as possible. Otherwise, the additional water 1 j entering the soil voids will have to be forced back out, extending [ ] the consolidation duration. However, after further discussion it 'g was agreed to by the consultants to proceed with~ filling of the pond frendiately, because the n.wount of river water available for filling is restricted. <+ p$ l' l H ._.7._.
J :' Lo- .. ue ~ . :. a- - Neeting Notes Es. 832 Paga 3 ? 5. genting Capacity -t. The consensus was that there is no bearing capacity problem, static .) or dynamic. However, if justification, in addition to the monitoring .'l data during preload, is required by the NRC, test pits may be dug
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to determine actual bearing capacity. Additional saeples from . borings af ter the preload are not recommended. 6. suggested Activities t The. highest priccity is to install the soil monitoring devices. The soil anchors at several depths should go in, first starting with 1 the SE corner of the building and then the piesometers could be hf l placed. The duct banks which appear to be restraining the building O'g ,i settlement should be isolated from the building as necessary. The qe$sj. l building construction should, continue, thereby providing more o weight on the foundations. Any gaps between the footing and the ? , inud mac would require grouting. The grouting would not be necessary D -i
- l prior to preload. It was pointed out that from a safety and a*
' building distress point of view, it would be advisable to grout existing gaps prior to releasing duct banka. It was also suggested q that the mud r.at be broken up prior to preload. '1 7. Preload Details I k The preload height should be about 20'-0", approximately equal to , the depth of the material to be consolidated. Physical limits restrict the preload depth to approximately 23 feet. The preload rate is not critical and even distribution would be adequate. The preload should be stopped at 10 feet for about a week to watch the monitoring, and then increased to 15 and 20 feet as necessary. It ~ l was suggested that a 20-foot berm with a 30 degree slope be used aroung the bulding where possible. Frost protection for the area to be preloaded was considered appropriate if required by weather j; conditions. 8. Possible Cause 1 l Consumer's asked the consultants for the cause of the excessive
- i settlement.
Dr. Hendron stated that there were in addition.co
- j nonuniform fill, erratic properties which may have been caused by too much variation in lift thicknesses. Dr. Peck said that the exact answer may be extremely difficult to determine. He added that material placed dry of optimum would later, with the presence of moisture, tend to soften the materials.' He also added that refilling of excavations from existing fills tends to be less adequate than the original fill. He said large areas to be compacted s
are better than small areas' and gave'the example of the dike versus the Diesel Generator foundation area. 7 m I g i I
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n '_ - - g) A F ga 4 j ;,. ]- 9. Cooling F;nd Dika A [ The op' inion of the consultants was that it is not necessary to i perform borings in the cooling pond dike. There is a possibility ~ ]\\. of hydraulic fracture. The monitoring information from the dike has shown no reason for concern. There has been no significant settlement since the 1-1/2-inch settlement in the southeast corner observed in early 1978. This is the best evidence that the dike is performing i satisfactorily. There also has been a detailed visual inspection made on the dikes wh'ich indicates no evidence of problems. 'l j
- 10. Liquefaction I
i There are some sand materials under the north side of the diesel j generator building. The boring blow counts in some isolated zones R indicate that the potential for liquefaction would have to be evaluated. Vibrofloatation is a possible solution for liquefaction 1 problems if they exist. ~ l
- 11. Proposed Instrumentation
[j** The proposed instrumentation to be used to monitor the structure, j soil, and utilities was discussed. The structure, including the ,1 generator pedestals, would be monitored by survey. Areas covered bypreloadwouldhaverodsencasedbysleevese'tendkastoavisible x point. Four of the existing cracks in the concrete structure will be monitored by electronic strain sages. The existing fill will be monitored by 50 borros anchors. The anchors will be placed at three levels within the fill'. There will also be some anchors placed outside of the preloaded area as settlement control..The ~ j borros anchors should be initially monitored on a daily basis. Sectiement p1,atforms will be'used through the preload to monitor I the. top'of ground. The pore water pressure will be monitored by 20 l piezopeter at approximately the same three levels, except that the s.and'longth is to be shortened to approximately 2 feet. 4 The utilities under the structare (condensate and service water .j pipes) would be monitored by drag through settlement devices. The [,1 accuracy of data is anticipated to be + 1/4 inch and a series of 4 readings would have to be made to develop a base line. Inclinometers ,l were proposed to monitor the lateral movement of soil and utilities ] but the soil consultants felt that they were not needed.
- 12. 51ab at Elevation 634'-0" d
The consultant suggested that grating be used inside the building instead of the compacted fill and slab to eliminate material placed above the foundation. The feasibility was to be investigated.by t ', Bechtel. 1 t V a 1
= rj M rtirs Estco Ko. 81 Pe233 5 j
- 13. Other Structures j.
The other structures founded on plant fill will be discussed following j the December 4,1978, meeting with the NRC.
- 14. Cogtact with NRC
~ A call was placed to Mr. Hood and Mr. Heller of the NRC by Mr. Cooks of CPCo; Dr. Peck and.Dr. Hendron, soils consultants; and Mr. l Ferris of Bechtel informing them of our progress and to set up a jobsite visit on December 3 1978, with a discussion the following ,'j day ACTION ITEMS: Bechtel 1. Proceed with preparations for preload as rapidly as ? possible. g Bechtel 2. Evaluate the feasibility of using a grating floor at ' el'vation 634'-0". a f Bechtel 3. Evaluate the potential for liquefaction. This item was j resolved with the consultants at the Nove er 18,1978, meeting held in Urbana, Illinois.. f I s B.C. McConnel sCHiss 12/1/1 yjg 3 J e i 'i 4 Lj I l'l l (, (' a. .8 e _pmm.mm. + ae _. ~ _. - _ _ - _ = =. _,. .__,~_~-__..__.____m__~... ~. e.,v e*e. e+ 9m*****#
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4 UNITED STATES I 8 NUCLEAM REGULATORY COMMISSION %, *.... j; s (s _. e.- l aun a c. e s j Oocket Nos.: 50-329/330 t .b 1-Mr. J. W. Cook i Vice President 'j Consumers Power Company 1945 West Parnall Road .j Jackson. Michigan 49201 }
Dear Mr. Cook:
1 SU8 JECT: REQUEST FOR AD0!TIONAL 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-t ing therefrom. 0Ge review is being performed with the assistance of the U. 5. Army Corps of Engineers. We and they find that the results of ( additional explorations and laboratory testing identified in Enclosure 1 (Request 37) are needed to support required geotechnical engineering studies. Detail.s on the extent of these studies will be provided shortly by separate correspondence. is provided in order that initiate planning of the required explorations in a timely manner. you may How. ,l ever we suggest you await receipt of these further detafis prior to l . physically beginning the explorations. Enclosure 1 (Footnote 4 of Table 37-1);also includes requests for advanced notification of the availability i1 .. a f certain samples. .t li At noted in ~our Request 37 of Enclosure 1, your position in previous l 'rssoonses to Requests 5 and 35 not to complete additional explorations, sampling and laboratory testing after preloading continues to be unaccept- ' abit to us. So that you might better understand our position, we offer ,( the following observatinns: t F (1) The preload prSram as completed on the heterogeneous materials which were placed for the purpose of structural fill is not necessarily an improveme'it, nor does it necessaril,y produce founda-tion soils of more uniform engineering properties, compared to the r soil performance Mich would have resulted if the material had been properly compacted'to tha~ original requirements estabitshed in the i Midland PSAR. (2) To develop reasonable assurance of plant safety, the required studies are needed to serve as an independent verification of the predictions l \\ j of future settlements an4 the conclusions of the preload program. t ) pt 1 i. p --1-v-e - - " - - - - " * " * * - " ~ ^ ' ' ^
.a u - > l.: i t Mr. J. W. Cook JUN 3 01930 ( (3) The required studies will permit art estimate of total and differential ,, settlement for involved structurec, and systems following drawdown .3 with the proposed permanent dewatering system. .I. (4) Certain aspects of the preload program, such as the complication feb M < 1 introduced by the simultaneous raising of the cooling pond reservoir. M'4 j present difficulties in our full acceptance of your conclusion of the preload program. i t also includes other requests for information which we and the c U. 5. Army Corps of Engineers need to continue our review. t~ j 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 newbrings and tests contained in parts of Enclosure 1. Should you require clarifications of these requests and positions, please contact us. ~ Sincerely.* 5 / M//NG A. schwencer. Acting Chief ( Licensing Branch No. 3 Division of Licensing
Enclosure:
As stated ? cc: See next page t, 1 I 6( 1 0 ~ _, _, ~. -'~ ~ * ~ ~ ~
s 9: i l' 4 s , f,' A -l ~g ( cci Michael I. Miller, E.iq. , t, 'Isham,' Lincoln & Baale > ' Suite 4200 '/ ~ i. .,1 First National Plaza
- l Chicago, Illinois 60603 1
Judd L. Bacon, Esq. j . Managing Attorney el Consumers Power Company ' ~ 212 West Michigan Avenue Ji Jackson, Michigan 49201
- i Ej Mr. Paul A. Perry, Secretary Consumers Powe,- Company L,j 212 West Nic!J ;an Avenue
>j Jackson.. Michigan 49201 Myron M. Cherry, Esq. 1 IBM Plaza Chicago, Illinois 60611 Ms. Mary Sinclair 5711 Sumerset > Drive Midland, Michigan 48640 I \\ Frank J. Kelley, Esq. l Attorney General l State of Michigan Environmental Protection Division 4 i 720 Law Buf1 ding Lansing, Michigan 48913 '] Mr. Wendell Marshall c Route 10 ..i Midland, Michigan 48640 q 1 L Grant J. Merritt, Esq. Thompson, Nielsen, Klaverkamp & James r-f 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 v 5
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Stiver Spring, Maryland 20910 1 Mr. L. J. Auge. Manager Facility Design Engineering j Energy Technology Engineering Center P. O. Box 1449 Canoga, Park, California 91304 3 Mr. William Lawhead U. S. Corps of Engineers NCEED - T 7th Floor 1 477 Michigan Avenua Detroit, Michigan 46226 8 ? 4 d n 4 5 .i
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) ( ADDITIONAL REQUESTS REGARDING PLANT FILL s.j 36. We have reviewed your response to Request 24 and find that information from additional boring logs is needed.
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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, 158, 15C and 27A) b. LOW-1 thru LOW-14 (14 holes) TW-1 thru TW-5 and PZ-1 thru PZ-48 (55 holes) c. d d. OW-1 thru OW-5 (5 holes) e. TEW-1 thru TEW-8 (8 holes) The logs should include date and method of drilling, the type and location of samples attempted. Also provide the locations, boring i logs and available test data of any exploration completed in 1979 and 1980 which has not yet been submitted. 1 37. Your position in previous responses to Requests 5 and 35 not to (RSP) i complete additional explorations, sampling and laboratory testing i V following the preload program continues to be unacceptable. We require that you complete as a minimum, the exploration and test-c 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 i Turbine 8uilding where piping and conduit have been placed on plant j fill. i .I 1;j J Li s1 a N. -) a 4 i i a y d- -==: = = =.:
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... a.J... -..... c. -... i......_. 2. m... ij ^ Page 1 of 2 m O Table 37-1 Request for Additional Exp,1 orations, Sampling and. Testing 2 F M Anticipated Geotechnical / 6 i Location M Depth f $,,pjg,9 Lab Testing 4 Engineering Studies to be Required Diesel Generator !Thrufillanda Classify samples For cohesive soils Bearing Capacity l Buildir.g iminimum of S' according to T D (Consolidated-Drained) Settlement (6 holes along ninto natural Unified Soils C-U (Consolfdated-Undrained) Piping Distortion i perimeter) iglacial till soils Classification Consolidation S/ System e 3 i For sands ii Dralned Direct Shear on both loose & der.se spect-s mens
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'l l Relative Density I i l 4 i il" Auxillary Building Same as above Same as above Same as above except Caisson Foundation (2 holes) add U-U (Unconsolidated-Design (Vertical and Undrained for cohesive Lateral Load Support)
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i !i Service Water
- Pump (I holeh Same as above Same as above Same as above except con-Pfle Foundation Design StructureAand He-I solidation testing would (Vertical and Lateral Load taining Walls (2 holes) l be limited to samples in Support) i
- I retaining wall foundations.
'Retalning Wall Stab 111ty & Settlement. ,l Cooling Pond Em-Extend thru fill For cohesive sofis bankments and a minimum of Same as above (7 holes along S' into natural C-D Consolidated-Dralned) Slope Stability L perimeter) residual soils ex-C-U Consolidated-Undrained) Fill compaction adequacy j cept hole no. S U-U Unconsolidated-Undrained) ll which should extend q to bottom elevation h of cooling pond. H L NOTES: See page 2 l H!j -
('l.. i [** Page 2 cf 2 1-u 1 Table 37-1 (continued) 3 -( NOTES: ,1) See attached Figs,37-1 and 37-2 for approximate boring 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. 1 jf 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 laboratory testing should be located at the completion and elevation . of the split spoon sampling program. The groundwater level should be recorded at the completion of drilling in all borings once the level has stabilized. ej Normal classification (e.g.. gradation. Atterberg Limits) unit weight ,4 and moisture content testing to be performed on representative samples from each significant foundation layer. This column pertains to lab testing in addition to the above mentioned tests. It is requested that at least one week notice be provided to the NRC before opening undisturbed samples to permit on site visual observation by Corps l of Engineer representative. ( SJ The maximum load should be great enough to establish the straight-ifne . portion of the void ratio-pressure curve.
- 6) Details on the extent of geotechnical engineering studies to be completed using the results of field and lab testing work will be provided in a separate letter.
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g* I. ( L i Attachment ' g}*% 5 '- OU UMTED STATES ' t. NUCLEAR REGULATORY COMMISSION q t,. ) m s= =orou.a.c.2oses u e, -...../ 1 s, - Docket Nos. 50-329
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and 50-330 j 1 l APPLICANT: Consusers Power Company FACILITY: Midland Plant, Units 1 & 2 4
SUBJECT:
SumARY OF JULY 18,1979 M ETING ON SOIL DEFICIENCIES AT THE / MIDLAND PLANT SITE i On July 18,1979, the NRC staff met in Bethesda, Maryland with Consumers / Power Company and the 8echtel Corporation to discuss deficiencies in the '} fill used at the site for Midland Plant, Units 1 & 2. Also present were representatives of the AC?.S staff. Meeting attendees are listed in 2 Ecclosure_1. In response to NRC requests, the applicant has documented in detail the presentations given during this meeting. The presentations are contained in S. H. Howell's letter to J. G. Keppler dated August 10,1979. In view of the August 10, 1979 letter, no sunmary of the presentations is contained herein. Rather, additional discussion consisting of coaments _ and questions given during.and following the presentations are sunmarized. During the presentation regarding remedial work in progress or planned (item 3 of the presentations), the staff noted that underground piping from the borated water storage tanks and service water lines pass under rattroad tracks, and that these and other. piping are subject to loads due to construction cranes and other traffic. The staff requested the applicant to describe the design features and other measures which assure that such piping is not subjected to excessive loads. The applicant will i respond at a later date. .9 The appiteant noted that it is performing laborator/ investigations of a the stainless steel piping removed from the condensate storage tank. pi This underground piping was found to be heavily corroded. It was notrt 3 that the injection piping from BWST is of the same composition and is W also unprotected from electro-chemical attack. The test-pits in the H tank farm area which are being dug to investigate the effect of the Q air discharged from underground pneumatic lines was also described. p Results will be reported' shortly. I, e 'b i-4 ui = li !i 'h f b--et ;WM L 'T' j .1 7 _g
g c 6( ( ( ~r l y i C""' 16 !979 Consumers Power Company ~ i 4 The staff noted that the response to its 10 CFR 50.54 requests for ac:eptance 3' .l. criteria for remedial actions (e.g., questions 4, 6, etc.) had not resulted il in identification of criteria in advance of the remedial action. Rather the l reply notes that the criteria will be determined during or after the remedial,d'p aj action. The staff stated that this approach by the appitcant does not provide ! d N for timely staff feedback at the outset, but rather the staff must await results of the program to deterentne what acceptance criteria were used and j if they are acceptable. Thus, the remedial action is being conducted entirely at the applicant's own risk. The applicant's presentation of the permanent site dewatering system (presen-q tation item 3.3) noted that the system is not designed to seismic Category I requirements, but that the monitoring aspects of the systam are safety si The NRC staff noted that acceptance criteria for the dewate 'ng grade. ] system are given in the Standard Review Plan (Section 2.4.13, Revision 1) and requested that the applicant address Branch Technical position HMS/GS3 1, " Safety Related Permanent Gewatering Systen:s", Revision 1, attached thereto. i i The appitcant will respond in the near future. The quality assurance plan i for implementing the dewatering system will also be provided in future reports. l Bechtel described the structural and seismic analytical investigations being performed or planned for the affected structures (item 4 of the presentations). 1 The staff noted that further review of the acceleration (g) value used for site design has been impacted by staff manpower restructuring for the TMI-2' investigations 'and that use of outside contractors for the Midland seismic review is presently being considered. The staff also noted that its present i review indicates some areas of disagreement with the appitcant's proposed 'j loads ccabinations.and design criteria for SSE and differential settlement, and with the treatment of cracks in structural walls. The staff will further j docunent these and other positions at a later date. Bechtel reported (item 7 of the presentations) the results of its investi-e4 gations into the case of insufficient compaction of the plant area fill, and 'j identified five causes considered to be the most probable. The applicant noted its agreement with the 3echtel findings. Bechtel noted that personnel were not included as a most prooable cause because its review of qualifications 4 and expersience of both Bechtel and US Testing personnel had shown presence of -) sufficient education, experience, and training to carry out the tasks assigned. q The NRC staff noted that it disagrees with Sechtel's finding that personnel h qualification was not a probable cause, and stated that further review of the t basis for this Bechtel finding will be needed. 1 Staff consnents regarding the QA/QC aspects (presentation item 8) were based upon the applicant's 10 CFR 50.54(f) responsas to quest, ion 1 by d letter of April 24, 1979: F 1 i 4 )L m
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( ( _1 ~ Consumers Power Company.. 4
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(1) The applicant's response in item B.1 of Appendix ! (page I-3) 3 states its conclusten that " Specifications C-210 and C-211 provide l sufficient criteria by which to ensure that the fill is adequately a 4 placed to prevent excessive settlement." The staf* noted its
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. disagreement with this statement. The staff noted, for example, s that its IE investigations show that the specifications did not require qualification of equipment used to compact material, the lift thicknesses permitted were excessive for adequate compaction, gj the moisture control was unclear and the compactive effort to develop 95". of compaction was internally in conflict within h. Specification C-210. .i (2)' The applicant's response in item S.2 of Appendix I (page I-3) i noted that letters, TWX's, telecons, and memoranda are often i used to clarify the intent of the specifications, and that "it is possible" that in some situations the clarification provided j through such methods may have modified the :pecification without j formally changing the wording of the specifications. The staff comented that a more positive statement appear 1. to be warranted based upon the findings of IE. Numerous examples where telecons and memoranda were used to change the requirements of the speci-fications without revising the controlled document itself was cited in IE Inspection Report No. 50-329/78-20 and 50-330/78-20. l IE found that not only did these memoranda change the require-ments of,the specifications, but in some instances, conflicted = with previous engineering directives. ] (3) The staff noted that its review of QA aspects was centinuing and that funther requests for information would be issued. At the conclusion of the presentations, the NRC staff noted that the information presented was significant to the present review, and requested that the applicant (ocument and submit its presentations, including copies of the viewgraph slides used. 1< 'l ~ l-/,, N r edu
- J Darl Hood, Project Manager q
Light Water Reactors Branch No. 4 ., j Division of Project Management )
Enclosure:
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-. y 1 ( ( DCLOSURE 1 ATTENDEES July 18, 1979 i 'l Consumers Power Comcany ' Bechtel* i G. S. Keeley
- T. E. Johnson (BPC)
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- 0. E. Horn P. A. Martinez (BPC)
.y T. Thiruveneadam K. Wiedner (BPC) i T. C. Cooke D. Riat (AA) W. R. Ferris (SF) i H. Wahl (AA) i NRC:NRR A. B. Arnold (SF) Lj B. Char (AA) D. S. Hood F. J. Hsiu (AA)
- 0. M. Gillen S. S. Afifi (AA)
R. E. Lipinski G. Richardson (BPC) J. Gilray A. J. Boos (BPC) F. Schauer J. R. Davie (G) L. Heller L. S. Rubenstein j Bechtel Consultants I NRC:0 ELD R. B. Peck R. Loughney R. Hoefling', C. H. Gould NRC:IE D. W. Hayes G. Gallagher 'J. B. Henderson I .1 . ACRS ~ 3 j
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P. Tam '1 BPC = Sechtel Power Corporation .{ AA = Ann Arbor, Michigan 0 SF = San Francisco, Calif. G= Gaithersburg, Nd. r ' f. e I ] g.. t .s
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