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ray 16, 1980 tE!40RA!Susi TOP.:
P. G. Shew.on, Chairman,111dland, Units 1 and 2 Subcom.ittee FP.04:
P. Tan, Staff Engineer SU:: JECT: UNRESOLVED SAFETY ISSUE - P00'l QUALITY OF FILL ltATERIAL U'MR VITAL STRdCTURES Tne attached dacunent describes events that took place around the Midland fn1ndation problem.s.
In su'.r.ary, tfic Staff has issued an order to Consumers Po er Company (CPC) prohibiting certain activities having to do with the Midland foundation. CPC has requested a hearing on the issues and a hearing uill be,hcld by the ASL3.
I believe this is an unresolved safety issue -- fill material of poor quality has been used under the contairsaent and other vital structures.
Unusual
,settlemant has been observed at the diesel generator building.
I recomend that your Subcomittee, or the full ACRS, revie,i this matter with the Staff and CPC in the near future.
Peter Ta'a Staff Engineer Attactraent:
As stated cc: ACRS Members M. Libarkin J. McKinley 8408010195 840718 A
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RICE 84-96 PDR omce)
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UNITED STATES
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NUCLEAR REGUI.ATORY COMMISSION '
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Docket. Nos. 50-339 50-330 v
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l Consumers Power Company ATTN: Mr. Stephen H.. Howell Vice President 1945 West Parnall Rodd Jackson, MI 49201
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G' entlemen:
This letter transmits to you an Order Modifying Construction Permits No.
This action is being taken as a result of findings CPPR-81 and No. CPPR-82.
by inspectors from Region III, Office of Inspection and Enforcement made during the period of October 1978 to January 1979, and the conclusions of the NRC staff after reviewing responses to the 10 CFR 50.54(f) request of March 21, 1979, regarding the proposed remedial work under and around safety-related The structures and systems at the site, some of which is currently underway.
Order pertains to the problems associated with the soil foundation materials at the site.
The first Notice of As part of the Order there are two Notices of Violation.
Violation is Appendix A which contains information concerning four infractions With several examples, all of which relate to the soil. foundation problems.
The second Notice of V'olation, Appendix B, contains information concerning an item of noncompliance which was determined to be a material false statement.
Actions that Consumers Power Company may take as a result of this Order are described in the Order.
Sincerely, Sincerely, 0
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Victor Stet 10, r.
Edson G.
ase Director Acting Director Office of Inspection Office of Nuclear Reactor and Enforcement l
Regulation l
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Enclosures:
1.
Order Modifying Construction Permits, CPPR-81 and CPPR-82 2.
Appendix A 3.
Appendix B CER-*F~E3 MAIL RETOPl. RECEIPT REQUESTED bA
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UNITED STATES OF AMERICA NUCLEAR ltEGULATORY COMISSION
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'CONSIMERS POWER COMPANY
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Docket No. 50-329 (Midland Nuclear Power Plant,
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50-330
'o Units 1 and 2)
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I ORDER MODIFYING CONSTRUCTION PERMITS 3
The Consumers Power Yampany (the Licensee) is a holder of Construction Permits No. CPPR-81 and No. CPPR-82 which authorize the construction of two pressurized water reactors 'in Midland, Michigan. The construction permits expire on October 1.,1981 and October 1,1982, for Unit 2 and Unit I respectively.
II the Licensee informed the NRC Resident Inspector at the On August 22, 1970, Midland. site that unusual settlement of the Diesel Generator Building had occurred. The Licensee reported the matter under 10 CFR 50.55(e) of the This notification Commission's regulations by telephone on September 7,1978.
was followed by a series of interim reports dated September 29, 1978, November 7,1978, December 21, 1978, January 5,1979, February 23,1979, April 3,1979, June 25, 1979, August 10, 1979, September 5,1979, and November 2,1979.
Following the September 1978 notification, inspectors from the Region III, Office of Inspection and Enforcement, conducted an investigation over the -
This investigation revealed a period of October 1978 through January 1979.
breakdown in quality assurance related to soil construction activities under and around safety-related structures and systens in that (1) certain design and construction specifications related to foundation-type material properties 9
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..l and compaction requirements were not followed; (2) there was a lack of clear 3-
' direction and support between the contractor'.s engineering office and construc-t tion sita as well as within the c,ohtractor's engineering office; (3) there was j
a lack of control and supervision of plant fill placement activities which contributed to inadequate compaction of foundation material; (4) corrective action regarding non'comformances related to plant fill was insufficient or inadequate as evidence by repeated deviations from specification requirements; and (5) the FSAR contains inconsistent, incorrect, and unsupported statements with respect to foundation type, soil properties and settlement values. The details of these findings are described in the inspection reports 50-329/78-12, 50-330/78-12 (November 14, 1978) and 50-329/78-20, 50-330/78-20 (March 19, 1979) which were sent to the Licensee on November 17, 1978 and March 22, 1979 I
respectively.
The items of noncompliance resulting from the NRC investigation are described in Appendix A to this Order.
In addition, as described in Appendix B to this Order, a material false statement was made in the FSAR in that the F'SAR falsely
- 1 stated that "All fill and backfill were placed according to Table 2.5-9.." This statement is material in that this portion of the FSAR would have been found e unacceptable without further Staff analysis and questions if the Staff ha'd*
known that Category I structures, ad been placed in fact on random fill rather h
than controlled compacted cohesive fill as stated in the FSAR.
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As a result of questions raised during the NRC investigation of the Diesel f,
Gere-a.o-Buf1 ding settlement, additional information was necessary to evaluate e
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the impact on plant safety caused by soil conditions under and around
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safety-related structures and systems in and on plant fill, and the Licensee's related quality assurance program.' On March 21, 1979, the Director, Office of I
Nuclear Reactor Regulation, formally requested under 10 CFR 50.54(f) of the Commission's regulati$ns information concerning these matters to determine whether action shoul[be taken to modify, suspend or revoke the construction Additional infonnation was requested by the Staff in letters dated permit.
- September 11, 1979 and November 19, 1979. The Licensee responded to these letters,.under oath, in letters dated April 24,1979, May 31,1979, July 9, 1979, August 10, 1979, September 13, 1979, and November 13, 1979.
The Licensee has not yet responded to the November 19, 1979 requests.
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Several of the Staff's requests were direct'ed to the determination and justification of acceptance criteria to be applied to various remedial measures taken and proposed by the licensee.
Such criteria, coupled with the details of the remedial action, are necessary for the Staff to evaluate the technical The information adequacy and proper implementation of the proposed action.
Therefore, based on nrovider by the lice'nsee fails to provide such criteria.
a revbw of the information provided by the Licensee in response to the Staff questions, the Staff cannot conclude at this time that the safety issues associa'ted with remedial action taken or planned to be taken by the Licensee.
Without the resolution, of to correct the soil deficiencies will be resolved.
these issues the Staff does not have reasonable assurance that the safety-related portions of the Midland facility will be constructed and operated without. undue risk to the health and safety of the public.
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y III Under the Atomic Energy Act c,f 1954, as amended, and the Commission's regulations, activities authorized by construction permits or portions thereof p:s t
5 may be suspended should the Cosaission find information which would warran the Commission to r[ fuse to grant a construction permit on an original applica We have concluded that the quality assurance deficiencies involving the -
tion.
settlement of the Diesel Generator Building and soil activities at the Midland
- site, the false statement in the FSAR, and the unresolved s. fety issue c a
the adequacy of the remedial action to correct the deficiencies in the soil a
construction under and around safety-related structures and systems are ade bases to refuse to grant a construction permit and that, therefore, suspensio of certain activities under Construction Permits No. CPPR-81 C
is warranted until the related safety issues are resolved.
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. Accordingly, pursuant to the Atomic Energy Act of 1954, as amende, an Commission's regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORD g
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subject to Part V of this Order, Construction Permits No. CPPR-81 and No b
CPPR-82 be modified as follows:
Pending the submission of an amendment to the application seeki (1) of the remedial actions associated with the soil activities for safety-li '
related structures and systems founded in and on plant fill material u
the issuance of an amendment'to Construction Permits jll i
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. -d and No. CPPR-82 authorizing the remedial action, the follhwing activities
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are prohibitad:
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(a) any placing, compacting, or excavating soil materials under or around saIety related structures and systems; s
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physical implementation of remedial action for correction of (b) soil-related problems under and around these structures and systems, including but not limited to:
(i) dewatering systems (ii) underpinning of service water building (iii) renoval and replacement of fill beneath the feedwater isolation valve pit area (iv) placing caissons. at the ends of the auxiliary building electrical penetration areas (v) compaction and loading activities; construction work in soil materials under or around safety-related j
(c) structures and systems such as field installation of conduits an'd 1
1 ij piping.
t Paragraph (1) above shall not apply to any exploring, sampling, or testing
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(2) of soil samples associated with determining actual soil properties on f '
site which,has the approval of the Director of Region III, Office of
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h Inspe::ior, a.d Enforcement.
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V The Licensee er ary person whose interest is affacted by this order my within 20 days of the date of this' Order request a hearing with respect to I
all or ary part of this Order.
In the event a hearing is requested, the issues to be considered will be:
whether the facts set forth in Part II of this Order are correct;
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.(1) and (2) whether this Order should be sustained.
e This Order will become effective on the expiration of the period during which a hearing may be requested, or in the event a hearing is requested, on the p
date specified in an Order made following the hearing.
b FOR THE NUCLEAR REGULATORY COMMISSION i
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Victor Stel b, Jr g. Director lMson G. Case, Agting Director Office of Inspect' ion pffice of Nuclear Reactor and Enforcement
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Regulation 1
Attachments:
1.
Appendix A 2.
Appendix B i
Dated 3t Bethesda, Maryland, 8
' this (,&
day of December, 1979.
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DEC 8 1579 Apoendix A A
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NOTICEOFVI0thTION Consumers Power Company Docket No, 50-329 Docket No. 50-330 This refers to the investigation' conducted by the Office of Inspection I
and Erforce.aent at the Midland Nuclear Power Plant, Units 1 and 2, Midland, Michigan, at your offices in Jackson, Michigan, and at Bechtel Corporation,
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Ann Arbor, Michigan'of a:tivities authorized by NRC License No. CPPR-81 and No. CPM-82.
Based on the results of the investigation conducted during the period December II,1978 through January 25, 1979, it appears that certain of your activities were not conducted in full compliance with NRC require-
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ments as noted below. These items are infractions.
10 CFR bO, Apptndix B, Criterion III requires, in part, that measures 1.
shall be established and executed to assure that regulatory requirements and tre design basis as specified in the license application for t
structures are correctly translated into specifications, drawings, procedures and instructions.
Also, it provides that measures shall be established for the identification and control of design inter-i faces and for coordination among participating design organizations.
CPCo Topical Report CPC-1-A, Policy No. 3, Section 3.4 states, in part, "the assigned lead design group or organization (i.e., the f
)
N3SS supplier, A&E supplier, or C)Co) assure that designs and materials are suitable and that tl.ey comply with design criteria and regulatory requirements."
CPCo is committed to ANSI N45.2 (1971), Section 4.1, which states, in part, " measures shall be established and documented to assure that the applicabie specified design requirements, such as a design i
basis, regulatory requirements... are correctly translated into specifications,' drawings, procedures, or instructions."
Contrary to the above, measures did not assure that design bases were included in drawings and specifications nor did they provide for the identification and control of design interfaces.
As a l
result, inconsistencies were identified in the license application i
I and in other design basis documents.
Specific examples are set I
forth below:
l The FSAR is internally inconsistent in that FSAR Figure 2.5-48 l
indicates settlement of the Diesel Generator Building to be on a.
the order of 3" while FSAR Section 3.8.5.5 (structural accept-ance criteria) indicates settlements on shallow spread-footings s
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DEC 6 1579 2-Appendix A j
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founded on compacted fill to be on the order of 1/2" or less.
The Diesel Generator Building is supported by a continuous shallow spread footing.
b.
The design settlement calculations
- for the diesel generator and borated water storage tanks were performed on the assumption of uniform mat foundations while these foundations were designed and constructed as spread footing foundations.
The settl$ ment calculations for the Diesel Generator Building c.
indicated.a load intensity of 3000 PSF while the FSAR, Figure 2.5-47, shows a load intensity of 4000 PSF, as actually constructed.
i d.
The settlement calculations for the Diesel Generator Building were based on an index of compressibility of the plant fill between elevations 603 and 634 of 0.001. These settlement values were shown in FSAR Figure 2.5-48.
However, FSAR, Table 2.5-16, indicates an index of compressibility of the same plant fill to be 0.003.
PSAR, Amendment 3, indicated that if filling and backfilling e.
operations are discontinued during periods of cold weather, all frozen soil would be removed or recompacted prior to the resump-tion of operations. Bechtel specification C-210 does not specif-ically include instructions for removal of frozen / thawed compacted material upon. resumption of work after winter periods.
PSAR Amendment 3 indicates that cohesionless soil (sand) would f.
be compacted to 85% relative density according to ASTM 0-2049.
However, Bechtel specification C-210, Section 13.7.2 required
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cohesionless soil to be compacted to not less than 80% relative
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density.
10 CFR 50, Appendix B, Criterion V requires, in part, that activities t
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affecting quality shall be prescribed and accomplished in accordance with docinented instructions, procedures or drawings.
I CPCo Topical Report CPC-1-A, Policy No. 5, Section 1.0 states, in part, that, " Instructions for controlling and performing activities
- i affecting quality cf equipment or operation during design, construc-tion and operations phase of the nuclear power plant such as procure-ment manefacturing, construction, installation, inspection, testing
... are documented in instructions, procedures, specifications..
. these documents provide qualitative and quanititive acceptance criteria for determining important activities have been satisfactorily accomplished."
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hJ CPCo is commited to ANSI N45.2 (1971), Section 6 which states, in part, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the
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Circumstances and shall be accomplished in accordance with thess instructions, procedures, or drawings."
f' a.
Contrary to the above, instructions provided to field construc-(
tion for substituting lean concrete for Zone 2 material did not I
jU address the differing foundation properties which would result L
in differential settlement of the Diesel Generator Building.
b.
Also, cointrary to the above, certain activities were not accom-plished according to instructions and procedures, in that:
(1) The compaction criteria used for fill material was 20,000 ft-1bs (Bechtel modified proctor test) rather than a compactive energy of 56,000 ft-lbs as specif.ied in Bechtel Specification C-210, Section 13.7.
(2) Soils activities were not accomplished under the continuous supervision of a qualified soils engineer who would perform in place density tests in the compacted fill to verify j
that all materials are placad and compacted in accordance with specification driteria. This is required by Bechtel Specification C-501 as well as PSAR, Amendment 3 (Dames and Moore Report, page 16).
3.
10 CFR 50, Appendix B, Criterion X requires, in part, that a program for inspection of activities affecting quality shall be established r
dnd executed to Verify Conformance with the documented instructions, procedures and drawings for accomplishing the activity.
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l9 CPCo Topical Report CPC 1-A, Policy No.10, Section 3.1, states, in part, that "wo'rk activities are accomplished according to approved i
procedures or instructions which include inspection hold points beyond which work does not proceed until the inspection is complete or written consent for bypassing the inspection has been received -
from the' organization authorized to perform the inspections."
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CPCo is commite'd to ANSI N45.2 (1971), which states, in part, "A
, program for inspection of activities.affecting quality shall be established and executed by or for the organization performing the activity to verify conformance to the documented instructions, j
procedures, and drawings for accomplishing the activity."
i-Contrary to the above, Quality Control Instruction C-1.02, the program for inspection of compacted backfill issued on October 18, i
1 1976, did not provide for inspection hold points to verify that soil l[
work was satisfactorily accomplished according to documented 1
i:s. ructions.
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10 CFR 50, Appendix B, Criterion XVI requires, in part, that mea-sures shall be established to assure that conditions adverse to quality such as failures, deficiencies, defective material and
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nonconformances are promptly identified and corrected.
In case of significant conditions adverse to quality, measures shall assure that corrective action is taken to preclude repetition.
CPCo Topical Report CPC-1-A, Policy No.16, Section 1.0 states, in part, " corrective action is that action taken to correct and pre-clude recurrence of significant conditions adverse to the quality of items or operations.
Corrective action includes an evaluation of the conditions that led to a nonconformance, the disposition of the nonconformance and completion of the actions necessary to prevent or reduce the possibility of recurrence."
Contrary to the above, measures did not assure that soils conditions of adverse quality were promptly corrected to preclude repetition.
For. example:
a.
As of January 25, 1979, moisture control in fill material had not been established nor adequate direction given to implement this specification requirement. The finding that the field was not performing moisture control tests as required by specifi-cation C-210 was identified in Quality Action Request SD-40, dated ~ July 22, 1977.
b.
Corrective action regarding nonconformance reports related to plant fill was insufficient or inadequate to preclude repeti-
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ti.on as evidenced by repeated deviations from specification f
requirements.
For example, nonconformance reports No. CPCo
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QF-29, QF-52, QF-68, QF-147, QF-174, QF-172 and QF-199 contain p
numberous examples of repeated nonconformances in the same areas of plant fill construction.
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APPENDIX B
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NOTICE OF VIOLATION Consumers Power Company Docket No. 50-329 l,
Docket No. 50-330 1
This refers to the investigation' conducted by the Office of Inspection and Enforcement at the Midland Nuclear Power Plant, Units 1 and 2, Midland,'
Michigan, at your offices in Jackson, Michigan, and at Bechtel Corporation.
Ann Arbor, Michigan, of activities authorized by NRC License No. CPPR-81 and No. CPPR-82.
P During this investigation cotducted on various dates between December 11, y
1978 and January 25, 1979, the following apparent item of noncompliance was identified.
The Midland Final Safety Analysis Report (FSAR) contains the following:
Section 2.5.4.5.3, Fill, states: "All fill and backfill were placed f
according to Table 2.5-9."
. Table 2.5-9, Minimum Compaction Criteria, contains the following:
II)
Comocetion Criteria p
Zone Soil
" Function Designation Tyoe Degree ASTM Designation Support of Clay 95%
structures ASTMD155g6T (modified)
&c (1) For zone designation see Table 2.5-10.
I-(2) The method was modified to get 20,000 foot pounds of compactive energy I
per cubic foot of soil."
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. Section 2.5.4.10.1, Bearing Capacity, states:
" Table 2.5-14 shows the p
contact stress beneath footings subject to ' static and static plus dynamic loadings, the foundation elevation, and the type of supporting medium for various plant structures."
j Table 2.5-14, Summary of Contact Stresses and Ultimate Bearing Capacity for Mat Foundations Supporting Seismic Category I and 11 Structures, contains, in part; the following:
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" Unit Supporting Soils O
' Diesel Generator Controlled compacted l'
Building cohesive fill."
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.This information is false, in that s. terials other than controlled compacted cohesive fill were used to support the diesel generator building and informa-tion presentAH1 concerning the supporting soils influenced the staff review of
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