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Y May 13,1983
' Note toi 'Ross Landsman Ron Cook.
c Darl Hood Joe Kane
SUBJECT:
/ ALLEGED' VIOLATION OF THE BOARD ORDER
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I am enclosing CPC's_ testimony on the alleged violation of the Board Order.
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An investigation of the alleged violation will be coming out.in-the future.
However, CPC may present their testimony before that time. Accordingly,.it is necessary for us to go cross-examination is appro:through CPC's testimony and determine where priate.
Please analyze the testimony and I will contact you shortly for your comment.
I am also providing a list of questions which should be addressed.
(1) Does Ross agree that minor excavations did not need specific HRC approval so long as the paperwork could be reviewed during-site visits?
(CPC testimony, p. 3)
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(2) k' hat is_a fireline pipe?
(3) Did the Staff ever indicate to CPC that the fireline and deep Q excavations were minor? (CPCtestimony,pp.3-5)
(4) Did CPC have any reason to believe the excavations were minor? (CPC testimony,pp.3-5)
(5) Does anyone recali the May 21, 1982 meeting in which Ross said specific approval was needed*before the deep Q duct bank excavation could begin?
'(CPCtesitmony,p.5)
(6) At the May 20 meeting, did NRC indicate that its technical concerns were-with the backfill and not with the excavation? (CPC testimony, p. 8)
(7) Does-the May 25 letter constitute approval for the excavation below the i
deep Q duct bank? (CPC testimony, p. 9) 8400020189 840'718
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- j-(8). Did CPC have any reason to believe the May 25 letter constituted approval for the excavation? (CPC testimony, p. 9) i
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(9) Do we believe either the fireline or deep Q excavations were minor?
%Q kg Michael N. Wilcove Attorney, OELD z
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UNITED STATES OF A! ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND [ICENSING BOARD In the Matter of:
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Docket Nos. 50-329 OM I.~:
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50-330 OM CONSUMERS ?OhER COMPANY
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Docket Nos. 50 329 OL (Midland Plant, Units 1 & 2 '
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50-330 OL TESTIMONY OF. JAMES A MOONEY AND R M k--n="R.
CONCERNING THE ALLEGED VIOLATIONS OF THE APRIL 30 ASLB ORDER AND TEE MARCH, 1982 CABLE-PULLING INCIDENT Ql.
Mr. Wheeler, would you please explain the controversy-involving the excavation below the deep Q duct bank and the excavation for the fireline relocation?
t A1.
In response to the Licensing Board's April 30, 1982 Ordec, the company issued a letter to Bechtel stopping all work affected by the Order.. No work covered by the stop work order was allowed'to proceed until the company deter-mined that Staff approval had been obtained and gave. author-s
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ization to proceed by means of issuing ' letters to Bechtel.
In late May, 1982, an excavatien permit system was as-tablished to ensure pro.per controls of excavation and to 4,
avoid damaging underground utilities.
Excavation permits were required for all excavations in Q-soils. - The permits included a block for sign-off by consumers' construction, r
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signifying that all necessary NRC approvals had been ob-e W
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tained.
The procedure authorizing werk by letter was also continued for work falling under the April 30 order, includ-
. ing excavations.'
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The use of letters was superseded on June 29,1982, by-a work permit. system.
The work permit system applied to all work covered.by the April 30 order.
This system also made use of for=s requiting sign-off by the company, indicating
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that NRC approval had been obtained.
After N titution of l
the work authorizatiozi procedure, both an excavation per=it and a work permit had to be secured before e2.cavation work
,could proceed.
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Between April 30 and early June, I took a nu=ber of specific excavation requests to Dr. Landsman for approval-prior to conpany sign-off of an excavation perr.it of work release.
Included among them were excavations for a freeze-hole extending 54 feet below grade, excavation of a 72-inch diameter pond fill repair, slope layback and auxiliary building deepseated benchnarks.
In the early part of June, I discussed with Dr. Landsnan the excavation permit system and the manner in whic.h the staff was approving work under With the creation of z.n excavation perit proc-the Order.
ess, we anticipated that the NRC' Staff could eventually find sufficient controls were in place to justify a broad work f
release for routine excavations at the site.
We believed h
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g that such2a work autho'rization was within the NRC Staff's
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powers under the April 30 Order.
On June 11,1982, Dr. Landsman 'and I discuss 6d the ex-
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cavation permit procedure.
Dr. Landsm'an, at that time, '
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, stated t tat he found the excavation permit procedure suf-ficient.
He indicated that Region III did not find it necessary to specifically review and approve all minor excavations before work started, but that he would want to review the paperwork o'n all excavations permitted between -
his site visits.
He also stated that the excavation permit procedura should be adhered to.
Based on 'M s discussion, I concluded that Dr. Landsman had given approval to go ahead with minor excavations, under the excavation permit procedures, and subject only to Staff review af er-the-fact.
We further understood thaf. Dr. Landsman wanted to review major excavations, such as the excavation for the serv 3.ca water underpiming, before the work ctarted.
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The fireline excivation was carried out to relocate a fire protection line to an area where it would not be 1
damaged by planned excavationc to replace and rebed service water piping.
The old fireline, located near the circula-tory water structure, was abandoned in place and a new line r
was installed at a nearby location.
The fireline was not a s
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category I pipe.
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The ' excavation below the deep-Q duct bank involved a crossing of the freezewall and an underground electrical duct bank, ofter referred to as the " deep-Q duct bank."
To protect the duct bank, it was necessary to discontinue the
'freezewall where it crossed the duct bank.
To prevent water
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from passing through this gap in the freezewall, a plug had c
to be installed below the duct bank.
The excavation down to the duct bank was 32 feet deep.
An additional excavation below the duct bank was necessary to inctall the plug.
WhileIdolotrecallspecificdiscussio,nsconcerning
,the permits in operation h'e're, our general practic'e was to
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hold internal discussions before sign-off on an excavation
. permit or work permit for the purpose of verifying that the work in question was authorized by the NRC.
Both the fire-
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line excavation and the excavation below the deep-Q duct i
bank occurred after my June 11 discussion with Dr. Landsman.
4, /' Both 'weFe~minoi excavatioYis~ ~which therefore did' not require
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g explicit NRC review andTapproyal~1lirloritB~commenTeme~ nit w a s
the~ work, but which would be subject to NRC review at a j,
later date.
Accordingly, the Company signed off on the i :
excavation permits and work permits for these two excava-tions in late July, 1982.
J At the time the Company signed off on these activities, i.*
I was unaware of Dr. Landsman's concern and desire that 4-
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these two activities not be treated _as minor excavations but i
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that. explicit review and approval be obtained for them.
Had I.known of his concerns, I would not have allowed the
-sign-offs to occur and the excavati$ns to proceed *without his prior review and approval.
since becoming aware of Dr. Landsman's concern about
'these excavations',
- I have learned that a Bechtel Re=edial Soils Group Supervisor had personal meeting notes from a May 21, 1982, exit meeting with Dr., Lands =an that suggest that-Dr. Landsman had,. requested that further approirals be obtained 'before Tehcavating under the. deep-Q duct bank.
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attended that meeting, but do not recall Dr.' Landsman expressing such a concern.
I was also unaware of the Bechtel Supervisor's notes until after this matter became an issue.
The Bechtel Supervisor was not an individual
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respcasible for deternining if NRC authorization had been
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obtained.
Once I became avire that Dr. Landsman was concerned about the excavations proceeding without prior NRC approval, I had the approvals for the work pernits withdrawn.
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Mr. Mooney, do you have anything to add to Mr.
Wheeler's testimony on this subject?
A2.
Mr. Weeler was. operating on the theory that
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Region III, through Dr. Landsman, was the final approval point within the NRC Staff for this work.
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and order memorializing a conference call on May 5,1982, explicitly stated that either NRR or Region III could approve the work.
Quite frankly, it was not eminently clear which Branch of the staff was ~ Exercising approval. authority.
C'ertainly,
' I believe that Mr., Weeler's practice of seeking approval through Dr. Landsman was permissible and prudent since Dr. Landsman was the NRC inspector closest to the work.
Q3.
Could ycu describe your recollection of the meetings referred to in Dr. Landsman's memo?
J A3.
With regard to the May 20, 1982 meeting referred to in Dr. Landsman's memo of August 24, 1982, I apparently had a different understanding of the nature of NRR's technical problems than did Dr. Landsman.
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Could you explain?
A4.
Yes.
The so-called deep-Q electrical duct bank is a safety-related electrical duct bank *~ located quite'daep in
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the ground.
The~ technical questions d'iscussed at the May 20 m'eeting concerned the nianner in which' this duct bank would be protected from damage at the location where it crossed
- the freezewall and*the requirements for backfilling the
' monitoring pits.
I understand that the freezewall has been previously described t'o the Board, so I will not repeat a -
description here It suffices to say that witihout pro-taction, the freeH'ewall could da= age the duct bank by caus-(
ing the soil beneath the duct bank to heave.'
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Initially, the Company intended to insert the freeze ele:ents in a =ac.ner which would have frozen the soil directly beneath the duct bank.
The ce=;any propsed to protect the, duct bank from any heaving which would have been caused by the 4
freezewall by excavating the soil directly beneath the duct bank.
However, the Co=pany abandoned this plan when it discovered that the duct bank was deeper than previously expected.
The depth of i
the duct bank precluded the, insertion of freeze elements at locations which would have insured the freezing of the soil beneath the duct bank.
At the May 20. meeting, the Company I
advlsed the Staff that the duct bank was deeper than expected and l /
l ls preposed an alternative plan, involving excavating the soils l
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below the duct bank and installing a plug, either of clay or
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' concretes which would serve in place of the freezewall at that
, location.
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At the May 20 meeting, the NRR representatives expressed concern with the manner. in which the Company would permanently "J.~.
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backfill the excavation around the duct bank, as well as excavations made to monitor the heaving of soil at other locations.
NRR was concerned that concrete would be harder than the surrounding soil and therefore might cause differential settlement if left there pe'rmanently.
Discussions relating to -
t Ms permanent backfill question were not completed at this meeting, but to my kno$ ledge, no one frem.the Co:pany understood NRR's concern as relati,ng to the excavation, as opposed to the permanent backfill.
This point is highly relevant, since the Company would not have permitted this excavation to proceed if we believed NRR had technical problems with it.
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After this issue was raised in Dr. Landsman's memo I was 2
4 advised that Mr. John Fischer, a Bechtel employee, had personal notes of the May 20, 1982, meeting indicating that the companys would n'ot proceed with excavating the pit below the duct bank 4
"until NRC approval."
I do not remember such a commitment being made at the meeting, nor do,I recall anyone from the Staff requesting such a commitment.
However, I,do not dispute that the i
statement apparently was made at the meeting.
When I left the May 20 meeting, I understood the need for i
further contact from NRR on the backfill, but felt that the
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Company and NRR were in agreement on the excavation itself.
However, quite apart rom my understanding of the meeting, NRR gave explicit approval for the excavation in a letter dated
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May 25, 1982, four days'after the meeting.
The May 25' letter states that excavations. directly beneath th'a deep-Q duct bank had -
been approved. ;The letter also makes a clear distinction between excavating and backfilling,,which at the time served to confirm my uhderstanding of NRR's concerr.s
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I had further discussions with representatives of NRR on this matter at a soils audit held July 27-30, 1982,-
r at Bechtel's Ann Arbor office.
As -my notes and the NRC neeting su=harf, dated Nove=ber 12, 1982, indi,cate, discussion at this ' audit once again focused on the backfill and did not relate to the excavation itsel' f.
At the audit, NRR again advised the Company that a report was necessary prior to permanently backfilling any of the encavation pits.
No such conditior. was, pit:ed on enc:vating soil.
'Q5.
Mr. Mooney, do y6u have anything to add on the fireline relocation questioni A5.
Mr. Wheeler explains his basis for believing this work l
had been approved.
The fireline relocation job, whD -
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clearly falling within the scope of the April 30
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only ancillary to the soils remedial work.
That
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say that proper controls could be ignored or that NRC approval was unnecessary.
Because the fireline relocation was essentially an ancillary task, I do not believe the Company had' discussions with NRR cof$cerning it.
Q6.,
Mr. Mooney, could you please describe yo views of the so-called able-pulling incident" of March, 982.
A6.
Because I has. personally involved
- these discussions, view of the, " cable /
I I wish to explain
-pulling" incident -
l referenced in the A tachments to Mr. Keepler's testimony.
This incident has~been the subject /of a for=al NRC' l
' investigation as to whe er material false shtesents were l '
made.
I believe that the incident arose because of ineffective co=munication between the Company and the NRC staff.
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The Cenpany proposed a qual.ity assurance plan for the auxiliary building unde /rpinning wo k to the NRC in a letter da'ted January 7, 198 and at a mee *ng with Region III on between the compan/ ver the next two January 12, 1982.
O onths, discussions l
1 y and the Staff con 'nued regarding which l
, unde: pinning activities were to be Q-li ted.
On Mar h 10, 1982, there was a meetin betwe company d NRR and Region III. ' At this meeting,
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say that proper trols could be ignored o at NRC approval was unnecessary.
Because-e fireline relocation N
was essentially an ancil$'
task, I do not believe the Company had'discussi. /
ons with NRR'concerning it.
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Q6.,
Mr. Mooney, could you please desi:: ribe your views of f.he so-called " cable-pulling incident" of March,1982.
' A6.
Because I was. personally involved in these discussions, I wish to explain my v'iew of the, " cab 5.e-pulling" incident -
referenced in the Attachments to Mr. Keepler's testimony.
This incident has been the subject of a formal NRC
' investigation as to whether naterial false siatements were I
=ade.
I believe that the incident arose because of ineffective co=munication between the company and the NRC staff.
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The co=pany proposed a quality assurance plan for the aux.iliary building underpinning work to the NRC in a letter da'ted January 7,1982, and at a meeting with Region III on January 12, 1982, over the next two months, discussions I
between the Company and the staff continued regarding which underpinning activities were to be Q-listed.
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on March 10, 1982, there was a meeting betwe Company and NRR and Region III.
At this meeting,
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3 Company sought to. define those underpinning activities which were considered safety-related and subj2ct to the quality assurance program and therefore needed to be Q-listed.
However, the NRC Staff did not acceht the classifications proposed by the Company and took the p'osition that all' soils
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a'etivities beginning with Phase 2 work should be Q-listed
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' except for specific items for which it could be shown, in a
- fashion acceptable'to the NRC, that there was a specific basis to justify non-Q treatment.
One area of misunderstanding between the'NRC Staff and the Company was the question of whether the Compaby agreed to the Staff's positien at the March 10 meethg.
Apparently some NRC Staff members believed that the Ccmpany had com-i mitted at that meeting that all to-go underpinning work would be Q-listed unless specifically excepted.
I and other Company e=ployees believe no such cc:=itsent was made.. I viewed this meeting as a chance to discuss the issue.with the'NRC Staff and not as one at which a commitment would be made.
I can recall ihdicating to the NRC StaIf that we l
understood the Staff's request for such a commitment and' that we would "get back to them on it.."
The NRC Staff's 1
meeting minutes do not indicate any such commitment, i
corroborating my recollection that no commitment was made.
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A second area of misunderstanding arose because of the.
failure to define instrumentation installation as either a
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part of Phase 1 or Phase 2 of the underpinning work.
The NRC Staff's position at the March 10' meeting was that they
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wanted all underpinning activities beginning with Phase 2 to '-
be Q-listed unless specifically excepted.
since instru-mentation had to be installed and functioning before the start of Phase 2 work, the Company believed that the NRC
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Staff did not require that the installation of underpinning instrumentation be cov'ered by the quality assurance program.
The Company had stated that calibration of instruments and checkout of the s'ystem would be Q-listed.
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A third area of confusion related to the co=pletion status of underpinning instrumentation on March 10 and 12, 1982.
At the March 10 meeting, Region III ihspectors formed I-tn'e impression that underpinning instraentation had b,een completed. 'The NRC investigation conducted to review this matter determined,that statements' made by the company at she Ma'y 10 meeh.ing were undarstood by several NRC personnel to mean " work had begun without giving a report on the status of completion."
t On March 12, 1982, I and others from the company initiated a telephone call to Region III Staff.
During this call, the Company 3.dentified,a l'ist of items which we
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believed could justifiably be treated non-Q.
The Region.III
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inspectors were provided a matrix which showed that instru-mentation inst allation was one of the items that was to be m -
non-Q.
With no intent to mislead the. NRC Staff, but meaning
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only to inform the Region III inspe~ctors that underpinning -
instrumentation worX had begun, Al'an Boos of Bechtel state'd, "our instrumentation is essentially well underway., Wiring has been pulled'-- raceway has been installed."
The Region III inspectors apparently understood these statements to mean that all wi' ring for the underpinning instrumentation had been completed, an unintended inference.
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The nisunderstandings and poor ce=nunications of March 10 and 12, 1982 cane to light during the March 17-19, I
1982 Region III safety inspection.
The NRC inspectors" dis covered that instrument!ation installation was in progress, not completed.
They then infer =ed the company that,this l
i activity was to be Q.
In response, the Co=pany suspended 4
j all underpinning instrumentation installation and reclassi-
- fied the activities as Q.
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!j-subsequent to 1;hese events, Mr. Cook had a number of ij discussions with the NRC Staff Management leading up to a March 30, 1982 meeting with Region III and NRR,.at which time the Company comm.itted to Q-listing essentially all of c
i the o-go underpinning work. *As a result of the March.30 a
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co=mitment by. Company Management,,instru=entation ' installed-and cables pulled without being covered by quality assurance requirements were upgraded to comply with *a11 quality assurance requirements.
Since March. 30, 1982, all
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underpinning instrumentation has.been i~nstalled pnrsuant to.
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quality program requirements.
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UNITED STATES f'
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NUCLEAR REGULATORY COMMISSION e
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January 12, 1984 i
Docket Nos. 50-329, 50-330 (10 CFR 2.206)
Ms. Billie Pirner Garde Government Accountability Project Institute for Policy Studies 1091 Que Street, N.W.
Washington, D.C. 20009
Dear Ms. Garde:
On October 6,1983. I issued a " Director's Decision under 10 CFR 2.206" (00-83-16) granting in part and denying in part the relief you requested in your letter of June 13, 1983 on behalf of the Lone Tree Council and others with respect to the Midland project.
In that decision I stated that I would not require a management audit at that time, but would continue to review infomation concerning the licensee's performance to determine whether an audit was required. For the reasons stated in the enclosed Confirmatory Order, Consumers Power Company will now be required to conduct a management appraisal of the Midland project. Accordingly, I have also issued the enclosed " Supplemental Director's Decision Under 10 CFR 2.206" (00-84-2).
For your infomation, I.have also enclosed a copy of the notice filed with the Office of the Federal Register for publication.
With respect to your letter of November 26, 1983 to Mr. Keppler and myself, which raised a number of questions concerning an independent management audit of Consumers Power Company, you should be assured that the appraisal will be a broad-based one. The staff will examine the proposal for the appraisal, with due regard for the issues of competence and independence of the proposed reviewer, and will detemine whether the proposal is satisfactory under the order.
It is the intent of Region III to receive public connents with respect to the appraisal.
With respect to your question regarding the reference to a " plan of action" in Region III's memorandum concerning the October 25, 1983, meeting between 7
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Ms. Bille Pirner Garde 2
NRC and Consumers Power Comoany, the " plan of action" was the staff's choice of words which was intended to convey Consumers Power Company's plans to improve management of the Midland project, a subject that was discussed at the October 25th meeting.
Sincerely,
- .?.';ug m Richard C. DeYoung, Director Office of Inspection and Enforcement
Enclosures:
as stated cc w/ encl.: James W. Cook Consumers Power Co.
Michael Miller, Esq.
Distribution (DD-84-2)
SECY---------------------by bluebag EDO 13229 OGC----------------------with J. Douglas, IE J. Lieberman, OELD-------incoming petition RCPB Reading D. Eisenhut, NRR ELD Reading R. Purple, NRR DCS J. Keppler, RIII IE:ES File G. Cunningham, ELD IE:EA File E. Christenbary, OELD S. Lewis, RIII R. Warnick, RIII g E. Adensam, NRRb W. Paton, OELD L. Cuoco, OELD J. Resner, PPM 8 J. Axelrad, IE G. Klingler, IE J. Stone, IE J. Taylor IE R. DeYoung, IE OELD RIII IE:ES)A N 0:FJ /(
DQASIP:IE DQASIP:IE DD-Lieberman Keppler GRKlingler Alx Trad Heishman Partlow Ta or DeVou 1/ /84 1/ /84 1/4/84
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UNITED STATES
. NUCLEAR REGULATORY COMMISSION oj wasumaron, p.c. asses e,
%,,,,. /a January 12, 1984 1
Docket No. 50-329 Docket No. 50-330 EA 83-118 Consumers Power Company ATTN: Mr. John D. Selby President 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
This refers to the investigation conducted by the Office of Investigations during the period January 3 through August 8,1983, of activities at the Midland fluclear Plant authorized by NRC Construction Pennit Nos. CPPR-81 and CPPR-82.
An enforcement conference was held with your staff regarding this matter on October 11, 1983.
This investigation revealed that Consumers Power Company (CPCo) had excavated soil material from below the deep "Q" duct bank and initiated fireline reloca-tion activities in "Q" soils without prior NRC authorization.
Further, the excavation of soil material below the deep "Q" duct bank was contrary to previous directives of the NRC staff which instructed the licensee that such cxcavation was not authorized. These actions violated paragraph 2.G of the Midland Construction Permits, as amended on May 26, 1982.
The violation described in the enclosed Confinnatory Order has been categorized as a Severity Level III violation as described in the General Policy and Procedure for NRC Enforcement Actions (Appendix C to 10 CFR Part 2). i;c civil penalty is being proposed for this violation; However, the attache:'
Confirmatory Order is being issuec.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part '.
Title 10, Code of Federal Regulations, a copy cf this letter and the enclosures will be placed in the NRC's Public Document Room.
The response directed by this Order is not subject to the clearance procedure of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, FL 96-511.
Sincerely, Richard C./0 Young Director Office of spection and Enforce
Enclosure:
Confirmatory Order CERTIFIED MAIL RETURN RELLiFT REQUESTED
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I Consumers Power Company 2
cr.w/ encl:
DM8/ Document Control Desk (RIDS)
Resident Inspector, RIII
.The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable. Ralph S. Decker, ASLB William Paton, ELD Michael Miller
. Ronald Callen, Michigan Public Service Comission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.)
Howard Levin (TERA)
Billie P. Garde, Government Accountability Project Lynne Bernabei, Government Accountability Project i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
In the Matter of
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Docket Nos. 50-329
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50-330 CONSUMERS POWER COMPANY
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(Midland Plant, Units 1 and 2)
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CONFIRMATORY ORDER I
Consumers Power. Company (the licensee) is the holder of construction permits CPPR-81 and CPPR-82 issued by the Atomic Energy Commission (now the Nuclear Regulatory Commission (the Commission)), which authorize the construction of the Midland Plant, Units 1 and 2 (the facility). The facility is under construction in Midland, Michigan.
II i
Sincethestartofconstruction,thefacilityhasexperiencedsignific[rt quality assurance (QA) problems. Although the licensee took corrective actions in each case, problems continue to be experienced in the implementation of its QA program.
1
2 On October 6,1983, the Director of Inspection and Enforcement issued a
" Confirmatory Order for Modification of the Construction Permits" which required that the licensee adhere to the Construction Completion Program (CCP),datedAugust 26, 1983, for the duration of the construction of the facility. 48 FR 46673 (October 13,1983). As more fully described in that order, the development of such a program was necessary to verify the adequacy of prior construction and to insure the adequacy of future construction in view of the identification of widespread QA problems in late 1982, the facility's history of QA problems, and the ineffectiveness of previous corrective actions to fully resolve these problems. An important aspect of the CCP is the third party overview by Stone and Webster Engineering Corporation which is required until the Regional Administrator, Region III, finds that the overview is no longer necessary to provide reasonable assurance that the facility can be constructed in accordance with Commission requirements. One element in any decision regarding the relaxation of the overview requirement will be a finding of confidence in the ability of the licensee's management to properly construct the facility in accordance with Commission requirements withcet a third party overview. Such a finding cannot now be made.
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3 III On December 6,1979, the Director of the Office of Inspection and Enforcement and the Director of the Office of Nuclear Reactor Regulation issued jointly an Order Modifying Construction Permits for the Midland plant. The order was based in part on a breakdown in quality assurance related to soils work at the Midland plant which had led to excessive settlement of the facility's diesel generator building. The licensee oemanded a hearing on the order, and the proceeding on the order was eventually consolidated with the proceeding oa Consumers Power Company's application for operating licenses for the Midland plant.
During the course of the proceeding, the Atomic Safety and Licensing Board issued an order that authorized the Director of the Office of Nuclear Reactor Regulation to amend the Midland construction permits to incorporate certain limitations on remedial soils work at Midland.
See Consumers Power Co. (Midland Plant, Units 1 & 2) LBP-82-35,15 NRC 1060, 1072-73 (April 30, 1982).
In accordance with the Board's order, the construction permits were amended on May 26, 1982 to include the Board-ordered conditions.
Among the restrictions imposed by the Board's order and the permit acerc-r.ent was a ccndition that the licensee "shall obtain explicit prior appro al from the NRC staff...before proceeding with the following soils-related activities...: any placing, compacting, excavating, or drilling soil materials around safety-related structures and systems."
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t Construction Permit Nos. CPPR-8'1 & CPPR-82, 1 2.G.(1) & 2.G.(1)a; compare L8P-82-35, supra, 15 NRC at 1072-73. On July 28, 1982, an NRC
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inspector discovered that the licensee had excavated soil from below the deep "Q" duct bank and had initiated relocation of the fireline in "Q" i
soils without prior NRC authorization. Excavation below the deep "Q" duct bank had begun on July 23rd and relocation of the fireline had begun on July 27th. Neither activity had received explicit prior approval from the NRC staff as required by the construction permits.
In fact, exca-vation of soil material below the deep "0" duct bank was contrary to prior directives of the NRC staff which instructed the licensee that such excavation was not authorized. Thus, excavation of the deep "Q" duct bank and relocation of the fireline by the licensee constituted violations of the construction permits.
IV The history at this site demonstrates that management has not been effective in providing the attention to detail and high quality stardards necessary to the proper construction of this facility.
In view of this history, including the violation identified in section 111 of this crder, I have determined that a management appraisal is required at this time.
~c licensee, in a meeting on Letober 25, 1983 with the Director of the Offict: cf Inspection and Enfer:ement and the Regional Administrator, Region 111, and in a subsequent meeting on January 4,1984 with the
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5 Regional Administrator, agreed to submit a management appraisal program to the Comission.. It is appropriate to confirm the licensee's comitment by order.
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V In view of the foregoing, pursuant to Sections 103,161(1),161(o)and 182 of the Atomic Energy Act of 1954, as amended, and the Comission's regulations in 10 CFR Part 2 and 10 CFR Part 50, IT IS HEREBY ORDERED THAT:
Within 30 days of the effective date of this Order, the licensee shall submit to the Region III Administrator for review and approval a plan for an independent appraisal' of site and corporate management organizations and functions nat would develop recomendations where necessary for improvements in management comunications, controls, and oversight. Upor approval of the plan, the plan shall be implemented and the scheduled milestone completion dates shall not be extended without good cause and the concurrence of the Region III Aoministrator.
The plan shall include at least the elements itemized below:
(1) An appraisal conducted by an independent management consultant crganization retained by the licensee to evaluate the licensee's
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a current organizational responsibilities, management controls, communications systems and practices, both at the Midland site and 7
between the corporate office and the site. The appraisal shall include a review of the licensee's site and corporate construction management and supervisory personnel involved in the Midland project to determine their capability and competency for managing construction activities consistent with regulatory requirements.
(2) A description of the appraisal program, the qualifications of the appraisal team, a discussion of how the appraisal is to be i
documented, and a schedule with appropriate milestones.
(3) The provision of recommendations for changes in the areas mentioned in Item 1 that will provide assurance that the licensee will implement NRC requirements.
The licensee shall direct the approved organization to submit to the Region III Administrator a copy of the report of the appraisal and recommendations resulting from the appraisal, and any drafts thereof, at U-the same time they are sent to the licensee or any of its employees or contractors.
Prior notice shall be given the Administrator of any meeting between the licensee ans zie organization-to disOJss the results, recommendations, or progress made on the appraisal.
In addition, the licensee shall consider the recommendations resulting from the appraisoi a
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and provide to the Region III Administrator an analysis of each such recommandation and the action to be taken in response to the recommendation. The licensee shall also provide a schedule for accomplishing these actions.
1 The Administrator of Region III may relax or terminate in writing any of the preceding conditions for good cause.
VI The licensee may request a hearing on this Order.
Any request for n. earing shall be submitted to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 within 25 days of the date of this order. A copy of the request shall also be sent to the Executive Legal Director at the same address and to the Regional Administrator, NRC Region III, 799 Roosevelt Road', Glen Ellyn, Illinois 601'7.
If a hearing is to be held concerning this Order, the Commission will i
issue an order designating the time and place of hearing.
If a hearing is held, the issue to be considered at such hearing shall be whether this Order should be sustained.
1
8 This Order shall become effective upon the licensee's consent or upon expiration of the time within which the licensee may request a hearing or, if a hearing is requested by the licensee, on the date specified in an crder issued following further proceedings on this Order.
FOR ThE NUCLEAR REGULATORY C0FNISSION fYY Richard C.( Young, Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this 12 day of January 1984 l
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H 00-84-2 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Richard C. DeYoung, Director In the Matter of
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Docket Nos. 50-329 CONSUMERS POWER COMPANY
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50-330
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(Midland Plant, Units 1 and 2)
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(10 CFR 2.206) i SUPPLEMENTAL DIRECTOR'S DECISION UNDER 10 CFR 2.206 l
On October 6,1983, I issued a " Director's Decision Under 10 CFR 1
2.206," DD-83-16,18 NRC
, which granted in part and denied in part l
a petition dated June 13, 1983, submitted by Billie Pirner Garde of the l
Government Accountability Project on behalf of the Lone Tree Council and others. The petitioners had requested that, among other relief, the Comission require a management audit of Consumers Power Company's perfomance on the Midland project.
In my decision, I detemined that a management audit was not necessary as a condition for going forward with.the l
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licensee's program to complete construction of the. Midland project.
However, I noted that the " staff [would] continue to review information 4
concerning the licensee's performance in other areas to detemine whether an audit is required." Slip op. at 12.
i I have completed my review of information related to a violation of a condition of the Midland construction pemits which was imposed by the Director of Licensing, Office of Nuclear Reactor Regulation in accordance I
with an order of the Atomic Safety and Licensing Board dated April 30,1982.
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s See Consumers Power Company (Midland Plant, Units.1 & 2), LBP-82-35,15 NRC 1060, 1072-73 (1982). This violation is an addition to the history of quality assurance problems at the Midland site which demonstrates that the licensee's management has not been effective in providing the attention to detail-and high quality standards necessary to assure the proper construction of this facility.
In view of this history, and the recently identified violation of the Midland construction pemits, I have now detemined that an appraisal of Consumers Power Company's management of the Midland project is required. The reasons for this action are explained more fully in the Confirmatory Order that I have issued today. The order requires F.onsumers Power Company, within 30 days of its effective date, to submit to the Region III Administrator for review and approval, a plan for an independent appraisal of site and corporate management organizations and functions.
The management appraisal is to develop recomendations where necessary for improvements in management comunications, control and oversight. Upon its approval, the plan will be implemented in accordance with a schedule of milestone completion dates.
i In view of the issuance of the Confimatory Order, the petitioners' request pertaining to a management audit is granted.
f b:-s Richard C.
Young, irector Office of pection and Enforcement Dated at Bethesda, Maryland this 12 day of January 1984 4
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NUCLEAR REGULATORY COMMISSION
[DocketNos.50-329and50-330]
CONSUMERS POWER COMPANY (Midland Plant, Units 1 and 2)
ISSUANCE OF SUPPLEMENTAL DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that the Director, Office of Inspection and Enforcement, has issued a supplemental decision concerning a petition dated June 13, 1983, submitted by Billie Pirner Garde of the Government Accountability Project on behalf of the Lone Tree Council and others.
' The petitioners had requested that the Commission, among other actions, require Consumers Power Company to conduct a management audit.
In an October 6,1983 decision (DD-83-16) which granted in part and denied in part other portions of the petitioners' requested relief, the Director noted that he would continue to consider the question of a management audit. The Director has now ordered the licensee to conduct a management appraisal of the Midland project. Accordingly, the Director has issued a " Supplemental Director's Decision Under 10 CFR 2.206" (00-84-2).
The decision is available for public inspection in the Comission's public document room, 1717 H Street, N.W., Washington, D.C., 20555, and in the local public document room for the Midland facility, located at the Grace Dow Memorial Library,1910 W. St. Andrews Road, I
Midland, Michigan, 48C40.
FOR THE NUCLEAR REGULATORY CO M ISSION l
ung,[ rector i
Richard C.
Office of In' ection and Enforcement Dated at Bethesda, Maryland this 12 day of January 1984
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NUCLEAR REGULATORY COMMISSION
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AUG 2 4 1932 f
MEHORANDUM FOR:
W. D. Shafer, Chief, Midland Section FROM:
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- 3. Landsman, Soil Specialist 3
SUBJECT:
VIOLATION OF ASL3 ORDER OF APRIL 30, 1982 When Darl Hood and Joe Kane were in Midland for an ACRS hearing, I asked fori a meeting to be held on site between NRR, Bechtel, the licensee and myself. The meeting took place on a Thursday,sfeernoon in the Re=edial Soils Trailer (May 20, 1982). The purpose of the meeting was to discuss q
numerous concerns that I had about ongoing work and future work.
2 One of the concerns disensced was a monitoring pit for what has come to be known as the deep "Q" duct bank. 'During that caeting both NRR and I expressed our concerns that what the licensee was planning was not approved, that is: to excavate below the duct bank. NRR only approved an excava-tion down to a duct bank approx 1=ately,.22' feet deep? This is documented in an NRC Tedesco to Cook letter dated February.12,_.1982, which references 6
a CPCo Mooney to,Denton letter dated Jh uary 6, 1982.
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Since the licensee usually does not know what is in the grg nf or where 7
it is, as usual the 22 foot duck bank was found at approxi=stRy 35 feet.
7 It also was not in the right location as evidenced by the monitoring pit sheet piling hitting one side of the duct.. In addition, while drilling a nearby devatering well, they inadvertently drilled into the duct bank, i
5-emptying the well drilling fluid into the turbine building through the duct.
S I had no problem with the licensee taking the excavation pie devn to 35 feet instead of the approved 22 feet, since the methodology of the approved excavation remained the same. NRR and I did have a problem with the licensee
, wanting to excavate below the duct bank to i= pervious clay in order to seal off the water flow, without first informing NRR of their plans and obtaining i;
their prior approval.
All of the a >ove was discussed during the meeting. The licensee was infor=ed that they could not excavate below the deep "Q" duct bank. The licensee indicated that they would submit something for-.a1 to NRR for approval.
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The following day, I warned them during the normal exit meeting and again during the summary'at the end of that meeting that they did not have prior NER approval. I asked if everyone understood what I was saying and they acknowledged.
Thefollowingweek,duringmyinspectiontoallowthelicenseetoactiv$te the free'za-vall, I warned them again that they could not dig below the deep "Q* duct bank because they did not have prior NRK approval.
Subsequently, af ter the activation of i:he freeze-vall, the licensee apparently decided that they had to seal off the water flow beneath the duct bank and.
proceeded to dig below the duce bank without NRR approvaE I'm not sure when excavation began, but I was on site July 28 when I discovered the excavation in progr'ess. The licensee, when informed of =y concern, issued a Stop Wrk Order on July 29, 1982. I wondered why they were so agreeable until I found out that they already had the excavation down to where they wanted it (the clay).
I informed the licensee during my exit on July '.10, 1982 that they were in direct violation of the Board order and their Constrection Per=1t.
To =ake matters worse, the licensee during the exit, said ths.t they discussed this with Messrs. Hood and Kane in Ann Arbor earlier that morning and had received
" Approval concerning the. technical adequacy" for what they were doing. I informed the licensee that they missed the point (basis of concern). My concern dealt not with the technical adequacy of what they were doing, but rather with their ASL3 order requirement to notify and receive prior staff approval before proceeding below the duct bank.
Subsequently, Mr. Kane indicated to me that they never even talked to him about this.
Mr. Hood indicated that they talked to him about something concerning the deep "Q" duct bank, but he in no way had given approval.
Subsequent to my leaving the site, the licensee began what I consider to be another unapproved excavation in "Q" soils. This excavation, which i-involves the relocation of a fire line was discovered on August 4,1982, during =y next inspectica. This excavation is along side the service water pump structure.
I have not had time to look into this =atter to better define the details, but as pointed out to you and Darl Hood, they have under-mined a duct bank, an unidentified pipe thrust block, and appear to be along side a safety related duct bank.
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Ross Landsman, Soils Specialist cc:
R. F. Warnick l~
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I Jasnam W Ceek Vice Pro: Mens - Projects, Engineering I,
and Consumetsen o
,w om. : ises w e Pern.a no.s. Jes===a. m 4esoi. tsi7) 7smuss May 10, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation i
Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MILi.AND PROTr.CT MIDLAND DOCKET NO 50-329, 50-330 ASL3 SOILS ORDER FILE:
0485.16.1, 0485.16.5 SERIAL:
17138 ENCLOSURE: 7220 C-45 (Q) YARD-9'ORK CLASS 1 FILL MATERIAL AREAS The Atomic Safety and Licensing Board issued an Order, dated April 30, 1982, imposing certain interim conditions on the remedial soils and related work at the Midland site. In accordance with the Order, Con'sumers Power Company stopped work at affected areas of the Midland site. Work which had previous NRC staff approval or which was otherwise not covered by the Order continues..
The Order covers remedial soils work, as well as "any placing, compacting, excavating, or drilling of soil materials around safety-related structures and systems." For a number of years, the Midland Project Drawing 7220-C-45 has been recognized as defining which soils at the Midland site ar4 safety-related. The enclosed C-45 drawing is being reviewed for compl&teness relative to the Board Order. The next revicion of the drawing will address the ultimate heat sink components and other appropriate areas.
In a conference telephone call on May 5, 1982, the Board concurred that in the absence of disagreement from the NRC staff, the term "around safety-related structures and systems" as used in the Order may be interpreted as coextensive with safety-related soils as designated on the C-45 drawing.
Remedial soils work previously approved by the NRC is continuing. Concurrence as to the scope of this work was obtained from Mr Darl Hood, and is as defined below:
I.
a.
phase I work (Auxiliarly Building underpinning),
b.
access shaft (Auxiliary Building underpinning),
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freeze wall installation, undarground utility protection,' soil c.
removal cribbing and related work in suppor4the freeze wall installation, freeze wall monitoring and c_reeze wall acuvacteer d.' installation and operation of the permanent site dewatering system, operation.of existing construction dewatering wells, e.
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FIVP proof ~ load test.
In addition to the above, NRR or Region III have specifically approved other 4.
work that is not presently underway. This work, as defined below, will be started at the appropriate time:
II.
a.
installation and activation of dewatering system for the service water pump structure, b.
the repair of cracks in the borated water storage tank ring wall, installation 'of Auxiliary Building monitoring system cable.
c.
In addition te the above, when the Order was issued Consumers Power was proceeding with certain other soils remedial work with full awareness and concurrence of the Staff; however, explicit written approval for that work had not been obtained. This work, as defined below, has been stopped in accordance with the order:
III.
a.
installation of deep-seated benchmarks, i
b.
installation. and operation of construction wells that were not previously operating-(previously installed and operating wells are ~
noted in Ie above),
installation of monitoring system instruments and mounting.
c.
4 Consumers Power Company believes it did have staff approval for this work because of the extensive review of the installation details of the systems and final agreement on the installation techniques. Accordingly, Dansumers Power Company requests the staff to verify in accordance with the Order its earlier
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concurrence so that work in these areas can be reactivated.
Confirming recent telephone communications, we have increased from 9 to 12 the number of deep benchmarks for monitoring, auxiliary building movements. Two of three additional benchmarks still need to be installed. These benchmarks will be installed in the same manner as the earlier nine, and the final system will be subject to final staff concurrence. Regarding benchmark installation, Consumers Power Company believes it had Staff concurrence following the auxiliary building audit, site visit and letter of March 22, 1982. The i
March 22, 1982 letter instructs the Applicant to have additional benchmarks installed before beginning Phase II work. Consumers now requests written confirmation of staff approval for the balance of this work.
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When the Order was issued, additional area dewatering wells were being installed to dewater the site for activation of the freeze wall and resulting
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construction.
,These wells are needed to complete installation of the freeze wall and dawater construction areas. They _were and WiTI'TE installed to the i
acceptance criteria agreed upon by the Staff for installing and operating
' dewatering wells in a safe marmer.
Consumers Power Company believes the
' agreement reached with the Staff on actejitTnce criteria for construction i
dewatering, together with the authorWation to IIEEtatf and operate the freeze wall, for which the dewatering is necessary, constitute previous staff approval of this work, and, therefore, requests explicit written confirmation at this time.
The work on the monitoring system instruments and mounting for the auxiliary building is presently stopped because the Region III concurrence has not been -
obtained.
We understand the remaining proposed work in this area will be reviewed by Region III in the near future. Such work is on the critical path and will start as soon as apprc fal is obtained.
The Order also requires that certain work specified therein be covered by a quality assurance plan approved by the NRC Staff.
The " Quality Plan for Underpinning Activities" (MPQP-1) was written specifically to provide nuclear quality assurance coverage of certain subcontractors which did not themselves have nuclear QA programs (Mergentime, Spencer White & Prentiss and their sub-contractors). MPQP-1 was approved by the Staff, subject to certain questions as to coverage, at a March 10 meeting with Consumers. Resolution of the coverage questions was achieved at meetings with the NRC Staff on "
March 30, 1982, as documented in a letter from J W Cook to Mr J G Teppler dated April 5, 1982. In the April 5 letter, Consumers agreed to place all to-go underpinning work, with certain specific exceptions, under the coverage of the quality plan for underpinning activities. The latest revisions of MPQP-1 encompass t. e installation and aperation of the structural monitoring system, as performed by Wiss Janey, in addition to the auxiliary building and service water pump structure underpinning.
Activites being performed wholly by Consumers, Bechtel or specific subcontractors which have in-place nuclear quality assurance programs are not specifically subject to MPQP-1, (which was designed for subcontractors without nuclear QA programs). We interpret the existing quality assurance programs and procedures of those organizations not covered by MPQP-1 as meeting the Order's requirement of an approved QA " plan".
Such quality assurance programs and procedures have been approved by the Staff previously or by CP Co under ptocedures normally used to review contractor QA programs. Of course, the specific construction implementing procedures for activities carried out under 3
these QA programs are subject to review by the Staff to the extent it deems necessary.
Y With regard to the items listed under III, above, the installation of deepseated benchmarks is befhg carried out by Woodward Clyde, which is subject to its owa quality assurance program and procedures approved by Consumers and previously subject to NRC Staff inspections. The construction dewatering wells under ites III(b) are to be installed subject to the quality requirements agreed upon with the Staff. As indicated above, the installation f
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of monitoring systems for the auxiliary building underpinning as performed by Wiss Janey (item C, above) is covered by MPQP-1, and as perfomed by Bechtel is subject to the overall site quality assurance program.
In summary, after issuance of the April 30, 1982 Order, the Company stopped certain work pending written confirmation of NRC Staff approval, previously given, that such work could be completed. Consumers Power Company requests Staff confirmation on these work activities so that they can be resumed as soon as possible.
aux JWC/JEB/dsb CC Atomic Safety and Licensing Appeal Board, w/o CBechhoefer, ASLB, w/o MMCherry, Esq, w/o FPCowan, ASLB, w/o RJCook, Midland Resident' Inspector, w/o RSDecker, ASLB, w/o SGadler, w/o JHarbour, ASLB, w/o GHarstead, Harstead Engineering, w/a DSHood, NRC, w/a (2)
DFJudd, B&W, w/o JDKane, NRC, w/a FJKelley, Esq, w/o RELandsman, NRC Region III, w/a WHMarshall, w/o JPMatra, Naval Surface Weapons Center, w/a W0tte, Amy Corps of Engineers, w/o WDPaton, Esq, w/o SJPoulos, Geotechnical Engineers, w/a TRinaldi, NRC, w/a HSingh, Army Corps of Engineers, w/a BStamiris, w/o m
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.' CONSUMERS POWER COMP NY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 17138 Dated May 10, 1982 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commissfun's Rules and Regulations thereunder, Consumers Power Company submits a summary of action-it has taken in response to the ASLB order dated April 30, 1982. Furthermore we are requesting explicit written approval for continuation of certain constructio'n activities.
CONSUMERS POWER COMPANY By
/s/ J W Cook J W Cook, Vice President Projects, Engineering and Construction Sworn and subscribed before me 12th day of May 1982 Barbara P Townsend Notary Public 4
Jackson County, Michigan My Commission Exp. ires September 8,1984 1 4 1
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j e-O Consumers Power Jernes W Cook Vsce Prasadens - Projeers, Engrneenng and Construssian oeneral offises: 194s west Parnest Roast. Jesason. MI 49201 + 1517) 788 o453 January 6, 1982 Harold R Denton, Director Office of Nrclear Reactor Regulation US Nuclear Regulatory Comniission Washington, DC 20555 -
MIDLAND PROJECT MIDLAND DOCKET NOS 50-329, 50-330 AUXILIARY BUILDING UNDERPINNING FREEZE WALL - t:12. CTS OF THE FREEZE PALL ON UTILITIES AND STRUCTURES FILE 0485.lt, SERIAL 15424 REFERE "ES:
(1) JWC00K LETTER TO HRDENTON, SERIAL 14318, DATED OCTOBER 28, 1931 (2) JWC00K LETTER TO HRDENTON, SERIAL 14869, DATED NOVEMBER 16, 1981 (3) JWC00K LETTER TO HRDENTON, SERIAL 14874, DATED NOVEMBER 24, 1981 ENCLOSURE:
EFIICTS AND MONITORING PROCEDURES FOR INSTALLATION OF FREEZE WALL DEVATERING AT MIDLAND UNITS 1 AND 2 In the referenced correspondence of October 28, 1981 (Reference 1) and during an October 1, 1981 meeting with the Staff, we presented a freeze wall concept for groundwater control under consideration for the underpinning of the auxiliary building. During a subsequent telephone discussion with the Staff on December 21, 1981, we proposed an approach for establishing protective measures for underground utilities and structures in the affected area of the freeze wall.
m In response to a Staff request made during the December 21, 1981 teleconsnunication, we are providing the enclosed summary of measures that we are planning for the protection of underground utilities and structures. The enclosed document contains: (a) the plans and elevations of the excavations at the affected utilities; (b) a cross-sectional view showing how the freeze wall is tied to the containment; and (c) reasons for using this approach.
Using this approach for protection of underground facilities isolates them from the effects of heave due to freezing.
With reference to the NRC's testimony on the remedial measures for the auxiliary building, transmitted to the ASLB in the NRC's correspondence of J AN 111987-oc0182-0001a100 3-82-061-Attach. 14
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2 November 20, 1981, the enclosed report responds ts the special licensing conditions identified in Table A.20, Parts 2a and 2b, and to Question 4 of 1 to this testimony. Regarding the special licensing conditions from Table A.20, Parts 2c and 2d for activation of the freeze wall, Question 3 of Attachment 21 to the NRC's testimony has been answered in Reference 2 of this letter. Our response to Questions 14 and 17 of Attachment 21 were provided in References 2 and 3 above and in the testimony of JPGould.
This completes our response to all parts of Ites 2 of Table A.20.
43 Mooney Executive Manager Midland Project Office For J W Cook JWC/RLT/dsb CC Atomic Safety and Licensing Appeal Board, w/o CBechhoefer, ASLB, w/o MMCherry, Esq, w/o FPCowan, ASLB, w/o RJCooh, Midland Resident Inspector, w/o RSDecker, ASLB, w/o SGadler, w/o JHarbour, ASLB, w/o DSHood, NRC, w/a (2)
DFJudd, B&W, w/o JDKane, NRC, w/a WHMarshall, w/o JPMatra, Naval Surface Weapons Center, w/a W0tto, Army Corps of Engineers, w/a WDPaton, Esq, w/o FRinaldi, NRC, w/a ESingh, Army Corps of Engineers, w/a BStamiris, w/o oc0182-0001a100
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1 EFFECTS AND MONITORING PROCEDURES FOR INSTALLATION OF FREEZEWALL DEWATERING AT MIDLAND UNITS 1 AND 2 l
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Consumers Power Company January 5, 1982
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This is a reply. to the special licensing conditions outlined in Table A.20, Part 2 (2a and 2b).
2A DOCUMENTATION OF DEFLECTIONS I' ROM EXISTING INSTALLATIONS This report contains results of an investigation requested by the NRC.
The purpose of the investigation was to compile
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documentation demonstrating that the freezewall, when acti-vated, will not adversely affect Seismic Category I structures, conduit, and pipes by causing ground heave or resettlement upon thawing.
Available information was reviewed from projects for which ground freezing was used and ground movement documented.
Of the cases reviewed, none are similar to this situation.
Most documented cases either provided documentation during only one segment of the project, or were in completely different soil conditions, frozen to the surface with no overburden, or for tunnel application where construction-induced settlement was monitored.
No documentation of utility monitoring was found.
Because of the high-permeability soil, as proven by numerous dewaterine; pump tests conducted at the site, the actual pressure on these utilities is expected to be small.
How -
ever, because no documented evidence of heave for similar installations is available and the expected movement of the soil and resultant stresses in the utilities cannot be calculated at this time, the response to Section 2B outlines the areas of concern and preventive measures proposed to eliminate any stresses on safety-related utilities.
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2B MOFITORING AND STRESS PREVENTION PROGRAM As stated -in Part 2A, no known guidelines can be found or calculated at this time to determine a projected movement to safety-related utilities; therefore, historically proven acceptance criteria for monitoring cannot be established.
In lieu of the NRC request to provide a field monitoring program to detect movemant to safety-related utilities and structures, the following alternative is proposed to elimi-nate the possibility of stress to these utilities.
AREAS OF CONCERN Figure 1 indicates the location of the free =ewall, area of Q-fill, and crossings of safety-related utilities.
As indi-cated on this figure, the freezewall does not cross under or influence any safety-related structures.
Although the freezewall will abut the containment building, it will not extend under~ it, therefore precluding any possibility of heave for this structure.
Most of the freezewall is in-stalled in non-Q areas.
It only extends into the Q area to form closure at the containment and, where required, to -
cross utilities on the southeast corner and east side of the power block.
The utilities included at these crossings are:
two sets of 26-inch service water lines, two electrical duct banks, and two sets of diesel fuel oil lines.
PREVENTATIVE MEASURES The, diesel fuel oil lines are 1-1/2-and 2-inch diameter steel pipes.
No preventive action will be necessary or taken to prevent movement of these lines, because these lines are in the top 4 feet of the ground surface and are therefore susceptible to normal ground frost movement.
Because of their small diameter they are more flexible and can tolerate movement due to frost heave.
To eliminate any possibility of stress on the service water lines or electrical duct bank during the freeze cycle, these utilities will be excavated within the projected influence area of the freeze wall.
The utilities will be excavated in a crib to provide a gap between the utility and
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the soil during the freeze cycle.
After the freezewall has stabilized, the utilities will be rebedded and backfilled.
A description of the three crossing areas follows.
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Crossing 1 Crossing 1 is composed of:
(a) One group of diesel fuel lines in the top 4 feet of the ground surface; and (b) the duct bank supply to the diesel fuel tanks.
Figures 2 and 3 indicate the utilities and crib excavation to be used in this area.* The diesel fuel lines as explained above require no. preventive action.
Crossing 2 Crossing 2 is composed of:
(a) four diesel fuel lines in the top 4 feet of the surface; and (b) two sets of two identical 26-inch service water lines.
The diesel fuel lines as explained above need no preventive action.
The two sets of service water lines will be excavated as shown in Figures 4 and 5.
Crossing 3
. Crossing 3 is limited to one duct bank.
This' duct bank is 22 feet deep and is the only safety-related utility line in the freeze zone.
This duct bank will be excavated as shown in Figure 6 and 7.
CONThINMENT BUILDING Figure 8 shows the interface of the freezewall at the contain-ment building.
As shown, the freezewall does not extend under the structure.
The containment is backfilled with I
- clean sand.
Clean', free-draining sand and high permeability materials are generally unsusceptible to frost expansion.
During freezing, water is forced out of the soil at the same rate as the freezing process, which results in a lower frozen water content without volume changes.
Also given the approximate stiffness and mass of this structure (120-foot diameter, at.10 ksf 'or 115,000 kips), it is evident that the influence of an approximately 3-foot-wide freeze section abutting the wall at the base of this structure will not adversely affect its stability.
MONITORING Utilities i-A monitoring rod will be installed in the ground at each crib excavation and monitored to determine if ground move-ment occurs during the freeze cycle.
The monitoring will be for information only because the utilities will not be affected even if heaving occurs.
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Containment The existing settlement monitoring program, which includes monitoring the -containment building, will be modified to include additional settlement readings at various phases of freezewall operation as follows:
a.
Before formation of the freezewall b.
Just after the wall has frozen c.
Just af ter the wall has unfrozen
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,s 5* 5* s' 5' DB / \\ / / / / / / 'h CONTAINMEWT / b L D G. Fit'iE7 WALL] l / top OF i / / / / / / / / / _ /, (- '/ } / Uc + h .'.(,4 & wswwf. .s,, / \\, / \\ 'd
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/ s l y / \\ / //, t CONSUMERS POWER COMPANY ~ MIDLANii PLANT UNITS 1 & 2 CONTAlMMENT BLDG PROFILE FIGURE 8 e e ,,-m 6 -M,*' f ,y ---.-,-..,m.--,-----,.,...----% w. -p-- e., j /- /, % \\) UNITED STATES 'I' NUCLEAR REGULATORY COMMISSION DI' WASMSNOTON. D. C. 20885 . J \\..... / NOV 12 582 ~ Docket Nos: 50-329 OM, OL and 50-330 OM, OL APPLICANT: Consumers Power Company FACILITY: Midland Plant, Units 1 and 2 ~'
SUBJECT:
SUMMARY
OF JULY 27 - 30, 1982, AUDIT ON SOILS REMEDIAL ACTIVITIES On July 27-30, 1982, the NRC staff and its consultants met in Ann Arbor, Michigan with Constners Power Company (the Applicant), Bechtel and their consultants to audit analyses, designs and preparations for remedial measures to correct the foundations and utilities on inadequately compacted fill soils at the Midland site.
Meeting attendees are listed by Enclosure 1.
On July 19, 1982, the' staff issued a draft of the second supplement for the Midland SER which primarily addresses the soils settlement review. A listing of the out-standing review items in this draft SSER was prepared by the applicant and served as the meeting agenda. The list was updated at the conclusion of the meeting to indi-cate which of those items had been included in the staff's audit. Enclosure 2 is the resulting agenda. The same-ntabered items from Enclosure 2 are discussed below in this stamary. Selected handouts provided during the meeting are shown as attach-ments within Enclosure 3.
General Items 1 - 5.
Not included in Audit 6.
NRC input into the final SSER will cover range of applied bearing pressures' static and dynamic loading A draft of FSAR Table 2.5-14, including bearing pressure data for the Auxiliary Building (AB), was provided (Attachment 1). The staff reviewed the table, noted that the infomation was acceptable and that once provided for the docket and verified, this item would be technically closed.
7 & 8.
The applicant was requested to determine that 1.5 x FSAR seismic response spectra analyses are conservative for the auxiliary building (AB), service water pump structure (SWPS), and borated water storage tank (BWST) in comparison to site-specific response spectra (SSRS).
l The applicant has not provided comparative plots of floor response spectra that were requested by the staff for all buildings (seismic margin review).
The NRC structural engineering staff reviewed calculations at 5 points of elevation for the AB to determine if 1.5 x FSAR response 3-82-061-Attach 16 i
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spectra enveloped the results obtained by using the SSRS. For these five points, the floor response spectra generated by the use of 1.5 times the FSAR spectra enveloped the respective l
floor response spectra developed from SSRS. Additional loca.
tions in this and other structures will be addressed as part of the seismic margin study.
i The applicant also noted that the use of the floor response spectra derived from the seisnic margin earthquake would be according to the seismic margin review criteria submitted to the staff by letter of September 25, 1981. The results of the seismic margin review will be submitted to the staff during the first quarter of 1983.
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9.
Test data on #9 and #10 Fox-Howlett rebar splices with up to 25 strain 4
Copies of ' test data up to 2% strain for #9 and #10 Fox-Howlett rebar splices were provided to the NRC during the audtt. Copies were also sent to the NRC consultant, Science Applications Institute by letter dated July 16, 1982.
The NRC found tre information acceptabIe after preliminary revi ew.
Pending subsequent NRC discussions with its consul-tant, this item may be closed.
10.
~ Identification, inspection, and repair procedures for concrete crack repair Criteria for concrete cracks were agreed upon and will be documented by the applicant in a letter in early August 1982 (Post script: see applicant's letter of August 2,1982).
The crack repair program applies to the DGB, SWPS, Contrcl Tower and Electrical Penetrations Areas of the Auxiliary Building and Feedwater Isolation Pits, which will be com-pleted prior to the first refueling of the plant.
It con-
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sists of the following three points:
(3) Repair by epoxy injection any cracks.in the structures which are below the permanent ground water table and which exhibit weeping characteristic. This repair will be performed from the inside of the structures.
(2) Coat the splash zone of the exterior surface of the-south wall of the Service Water Pump Structure which is in contact with cooling pond water with water-proofing compounds. The waterproofing compound will be one of the three compounds recommended by con.
sultants in their report " Effects of Cracks on Serviceability of Structures in the Plant",
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3-(3) Repair by epoxy injection existing cracks which are 20 mils and larger and apply a sealant to the sur-faces of the concrete walls in the following acces-sible areas (i.e. areas where removal of soil or installed equipment or installed components is not necessary to perform the repair).
ihe extent (length) of the crack that will be injected with epoxy will include at least that portion with crack width of 10 mils or larger.-
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Prior to the initiation of repairs, all cracks 20 mils and larger and weeping cracks in the applicable areas will be identified. A verification of this identification to a tolerance of +5 mils will be performed. This verification and subsequent will be in accord-ance with the quality program. The material for structural epoxy
, adhesive will be ".concresive-1380" manufactured by Adhesive Engineering Company, or equivalent.
7he areas to be repaired for each applicable building are as follows:
DG3 (a) All accessible interior reinforced concrete walls.
(b) All accessible exterior concrete walls.
CT&EpAs (a) All accessible exterior concrete walls.
SVpS (a) All accessible exterior walls.
11 & 12. Not included in audit.
Auxiliary Buildine 1.
Resolution of allowable vertical differential settlement and strain that will stop underpinning construction and require installation of temepor-ary suppirts The NRC staff reviewed the allowable settlement calculation resulting from analysis of the construction condition usir.g a subgrade modules of 70 KCF and analysis of reduced support along the EPA due to tunneling (Attachment 4). provides definitions of " alert", " action" and "requalify" levels which were agreed upon for underpinning activities. Attachment 3 provides numerical values which were agreed.upon.
The levels apply to Phases I~1, III, and IV.
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This item was accepted by the staff.
2.
Compaction control specification for granular fill beneath feedwater isolation valve pits (FIVPs)
It was agreed that the fill beneath the FIVP will be tested using the procedures outlined in the Seabrook FSAR. A copy of a similar FSAR section was provided by the hRC. It was also agreed that the fines portion of the fill shall be non-pl astic. This will be verified by the resident geotechnical engineer by appropriate testing (hydrometer of Atterberg limits). The backfill will be properly moisture conditioned by soaking immediately prior to compaction. The soaking means will be approved by the resident geotechnical engineer.
Compaction acceptance criteria will be 95 modified proctor or 85: relative densit'y (whichever testing standard results in the maximum dry density) based on tests perfor ned prior to pl acement. The applicant also committed to performing a laboratory c rnpaction or relative censity tes to estaclish maximum dry density on soil material taken from each field density test location. Bechtel compaction control specifi-cation will be revised.
Additional compaction equipment (e.g. self pro;ielled double drum compactor) will be qualified by the test fill method.
3.
Methodology for transferring final ioads to per-nanent underpinning wall' Preliminary copies of Mergentime/Hanson Drawings 5-74 and S-74a (see SSER #2, Appendix 1) not yet reviewed by Bechtel, were provided for staff review. Analysis of the permanent wall and preliminary design details were also reviewed. The' review included methodology, rebar stresses in critical areas, and connection to existing structure. The staff found these items to be acceptable.
The transfer of loads will be accernplished by the use of hydraulically actuated steel jacks that are incrementally increased to the specific loads determined by the struc-tural analyses. When the predetermined loads have been developed by the jacks, the loads will be maintained and
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locked off provided that the following criteria are met:
(1) The pier will be loaded to 125% of its specified jacking load and continued at the load until the relative movement between tha top of the pier and the underpinning structure is less than 0.01 in.
in a continuous I hour period. When this con-dition is satisfied, t
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(2) The pier load will be reduced to 110% of its specified jacking load and continued at that load
- until the relative movement betweer. the top of the pier and the underpinning structure is less than 0.01 in for a continuous 24-hour period. When this condition is satisfied, the pier will be locked off.
(3) Jacking loads for the permanent underpinning will be maintained at the specified value for at least i
30 days.
(4) A semilogarithmic plot of settlement versus time will be. developed to allow determination of when secondary consolidation has been reached.
(5) The settlement increment in the last 30 days of sustained load will not exceed 0.05 in.
(6) The settlement in the last 10 days of sustained load will not exceec 0.01 in.
(7) Wedges to be used for the permanent wall will be
- driven tight and perman~ently welded in place. In case a predicted jacking load is not obtained (when a 0.03-in.. upward movement of the existing structure occurs) jacking loads should be reduced to 80% of the load at which the movement occurrec and this load will be used in the analyses to determine subsequent jacking loads.
i' 4.
Updated scope of construction for Phases III and IV The plan which describes the construction scope (Drawing 7220-SX-0-0101) (see SSER #2, Appendix I) was reviewed. A discussion was also held regarding construction sequence. The staff found these matters to be acceptable.
1 5.
Resolution of pier and plate load test details on maximum test load, i
locations, and time for perfccming test i
The load test will be performed on Pier W-11.
The pro-posed load sequence is to jack the load from 0 to 50% of the bearing pressure allowed for the seismic leading combination, then decrease the load to 25%, and then increase the load to 130%. The staff agreed that no additional plate load test is required. The staff found these details to be acceptable.
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Long-term settlement monitoring plan during plant operation This is a technical specifications item. The information will be provided to the NRC as part of. the FSAR technical specification submittal in Octoter 1982.
7.
FSAR docmentation on as-built conditions This is a confirmatory item which will provide the. level of construction information typical of an FSAR. The information will be provided to the NRC once the appro-priate construction stage has been achieved, 8.
Design modification at freezewall crossing with auct banks y
The applicant had previously conmitted to provide a report addressing the installed surcharge loading pro-gram, monitoring results and backfill techniques.
The proposed metnod for backfilling monitoring pits will be provided prior to accom;11shing the work.
This carryover item from earlier meetings continues as a confirmatory issue.
9.
Resolution of required depths of construction dewatering wells The applicant agreeds with a staff position that, when excavating in cohesichiess (natural op fill) soils, the groundwater will be mai'ntained 2 feet below the advance of excavation.
In addition, a probing program will be used in selected piers. As a minimum, these piers include E12, W12 E10, W10, E7, W7, E4, W4, CT1, CT6, and CT12. Test holes between 1 in, and 4 in. in diameter will be advanced to a depth of 5 ft beneath the proposed bearing level (from a level 5 ft above the bearing level) in these 11 selected piers to determine whether groundwater under pressure exists in sufficient volme to require special pier dewatering. It water pressures are low, excavation to the bearing level will continue. If water pressures are shown to be high in the test holes, special dewatering i
(e.g., wellpoint or other suitable means) will be used v
to lower the water table at that pier to at least 2 ft below the bearing level. The hole beneath the final bearing level will be grouted. Although the available information indicates that the bearing strata is a fairly homogeneous hard clay, it is possible that special pier dewatering will be needed. These holes will be used n
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7 by the applicant as a conservative measure to confirm subsurface conditions before the bearing level is reached.
Interpretation will be done by the resident geotechnical engineer. This item is acceptable to the staff on this basis.
10.
Monitoring matrix showing allowable settlements and strains
' An updated copy of the monitoring matrix (Bechtel Drawing 7220 C.1493(Q), Rev.1) (Attachment 7) was provided. Alert, action and requalify levels will be added as agreed above ( AB Item 1).
The staff agreed that no alert or action level needs to be established for monitoring strain. However, the strain data are considered supplementary to understand the behavior of the building and strain levels greater than 0.0010 in/in are a factor to be considered in the rtising of the alert and action settlement levels. This item is acceptable to the staff on this basis.
11.
Electrical penetration' area (EPA) and control tower (CT) relative horizontal movement criteria The NRC staff reviewed drawings showing the gap detail between the EPA /CT and the turbine building (TS).
The
'ainimum gap between structural members of the CT and TB
The staff agreed that no acceptance criteria will be required for horizontal movement during underpinning.
Data from the horizontal instrumentation measurenents will be recorded and used as supplementary infonnation to the differential settlement records in the overall evaluation of structure movement during underpinning work.
12.
Changes in pier configuration The applicant has determined that piers CT4X and CT9X located along Column line K at 5.9 and 7.2 will not be e
required. Piers will be required at H and 5, and at Hk and 8.
The NRC staff reviewed Bechkel Drawing 7720-SX C-0101 (Rev'. 0) and Mergentime/Hanson drawing 5-74 (Rev.
- 2) showing the details of these piers (see SSER d2, Appendix I). This is acceptable to the staff.
13.
Details on stiffened bulkhead during drift excavation The NRC staff reviewed and agreed with the calculations of the drift / stiffened bulkhead design. The staff also h
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. agreed to constructing the drift support system in 2-foot increments, with lagging and tight backpacking
- completed up to the bottom of the EPA foundation slab an( with an excavation bench on the FIVP side.
14.
As-built plan for deep-seated benchmarks The NRC staff reviewed Bechetal Drawings 7220-C-1490 and C-1491 (Attac!nent 7) showing as-built locations of the AB deep-seated benchmarks and found them to be technically acceptable.
'15.
. Review of Specification 7220-C-200, Emergency Actions The flow charts for the emergency actions of Specifi-
- cation 7220-C-200 were reviewed in' detail. The staff found the flow charts to be acceptable.
Service Water pumo Structure 1.
Complete staff review of sliding and lateral soil pressure calculation,
under dynamic loading The NRC staff completed review of the sliding and lateral soil pressure calculation. Seismic loads equal to 1.5 times the FSAR SSE loads were used and were found to exceed $5RS loads. Factors of safety j
against sliding were 1.45 (N-S direction) and 1.50 (E-W direction), which exceed the staff's minimum requirement of 1.1.
This technical item is closed.
2.
Resolution of pier and plate load test details'en maximum test load,
' locations, and time for performing test The load test will be performed on Pier 1 (east side). The proposed load sequence is to jack the load frem 0 to 50. of the bearing pressure allowed for the seismic loading cm-bination, then decrease the load to 25%, and then increase the load to 130t. The staff agreed that no plate load test will be required. This technical item is closed.
3.
Resolution of required depths of construction dewatering wells For monitoring of construction dewatering at the SWPS,12 piezometers will be provided. Six will be sealed in the zone from el 570' to el 590'.
Soil sampling will be con-tinuous frcm el 570' to el 585' in borings.at the location of the six perimeter piezameters. The other six will be installed at the subcontractor's discretion.
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9 The water surface will be maintained 2 feet below the bottom of pier excavations if sand is present within 8 ft of the pier foundations as indicated by the continuous sampling in the six perimeter piezometers. If sand layers are identified in the exploratory borings for the piezo-meter installations, the wells will be lowered to maintain the 2 foot requirement. The results of the explorations and the final installation depths of the dewatering wells are to be provided to the NRC staff when available. This technical item is closed.
4.
Methodology for transferring loads from jacks to permanent wall and locking off Drawing 7220-C-2035-Q Rev. 2, with the relevant parts of Specification 7220-0-194 showing final lead transfer pro-cedures, were reviewed by the NRC staff and found to be acceptable. This technical item is closed.
5.
Long-term settlement manitoring plan during plant operation This is a technic [1 specification issue. The information will be provided to the NRC as part of the FSAR technical specification subt;ittal in October 1982.
6.
FSAR docunentation on as-built conditions This is a confirmatory item with technical issues resolved.
The information will be proviced to the NRC once the appro.
priate construction stage has been achievec.
6a.
Strain monitoring to measure acceptable allowable strain The NRC staff's evaluation of the applicant's June 14, 1982, submittal indicated the proposed 5/16 inch displacement (extension) criterion over a si.ngle 20-foot gage length was-not acceptable and the staff recommended that several gages of shorter length be installed to permit identification of the more highly stressed sections.
In the meeting of s
June 25, 1982, the applicant comitted to using four 5 foot long gages in place of or in addition to the single 20-foot gage. The action and alert limits for the 5-foot long gages will be based on the yield strain of the reinforcing steel.
7.
Staff input into the final SSER will describe computed earth pressures under both static and dynamic loading and design methods Review of computed earth pressures was completed. This technical item is closed.
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, 8.
ihe NRC staff is,to review and evaluate the applicant's analysis as identified in response to Request 2.8 of Enclosure 8, NRC letter dated 5/25/82 (interaction of circulatirg water and SWPS wall).
The NRC staff reviewed the drawing showing the structural gap between the circulating water intake structure (CWIS) and the SWPS, and compared this gap with the predicted deflections for each structure under earthquake loads. The 1 in, minimum gap is sufficient to accomdate the relative calculated gap of 0.518 in. Simarily, the 1 in, gap between the SWPS and the cooling pond retaining wall accomodates the calculated relative gap of 0.25 in. during a SSE. This item is closed.
9.
Check dowels for shear and tension capability 1
The staff reviewed the design calculations, discucsed the design methodology, and determined the shear and tension capability of connections for the underpinning to the existing structure The items were found to be acceptable.
This item is close1.
Berated W.ter Storace Tank
- Long-tenn settlenent monitoring plan during plant operatien 1.
This is a technical specification issue. The information wi-il-be provided to the NRC as part of the FSAR technical specification submittal in October 1982.
2.
FSAR doctnentation on as-built conditions This is a confirmatory iten with technical issues resolved.
This information will be provided to the NRC once the 4'
appropriate construction stage is achieved.
3.
Staff calculational review for governing leading combinations in structural design The NRC staff reviewed the calculation for design of the new ring beam foundation for applicable load combinations.
The governing load combination is:
i i i U = 1.40 + 1. 4T + 1.4F + 1. 7L + 1. 7H + 1. 9E 1
where component loads are identified by FSAR Section 3.8.6.3.1.
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The staff also reviewed the methodology used for design of a typical section considering forces and moments and found it to be acceptable. Additional information of a confirma-tory nature will be provided as part of the seisnic margin study.to denonstrate the adequacy of use of 1.5 times the FSAR response spectra relative to use of SSRS.
Underornund Pipino 1.
Staff evaluation of previously submitted reports on underground piping not completed The NRC staff and its consultant from ETEC reviewed the calculations for stresses due to seismic and settlement
'a f fects. The staff agreed witn the assumptions, method-
~
ology, and results of the analyses.
The staff completed its geotechnical review of previously submitted reports. The applicant agreed to ad five additional settlement and strain monitoring stations as requested, plus settlement markers at each end of transi-tion zones of replaced /rebedded pipes as shown on Drawing 7220-SX-C-745 (see.SSER #2, Figure 2.11). The five addi tional settlement and strain marker locations are station 1 + 32 and 3 + 15 for line 26"-0MBC-15; station 1 + 55 for line 26"-OHBC-20; station 0 + 80 for line 26"-OHBC-55 and station 3 + 00 for line 25"-0HBC-54 The The applicant also agreed to change the monitoring frequency to once per month for the first 6 months of plant operation.
The frequency of re.adings will be lengthened to the 90 day interval following the intial six month period if the settlement readings have stabilized (not larger than 0.10 inch change from the previous reading).
This will be written into the technical specifications.
This item is closed.
2.
The applicant's proposed reinstallation of 26-inch and 36-inch diameter pipes including review of analysis, properties of backfill, extent of excavation, details of transition, and controls during consturction The staff consultant visited the site and observed the s
arrangement of the service water piping in the SWPS.
The design approach for reinstallation of the service water pipe was reviewed and approved. The applicant pro-vided a preliminary stress sunmary table for the piping to be reinstalled. The final table will be provided by l
August 20, 1982. Drawing 7220-SX-C-745 was marked to i
show the settlement and strain monitoring locations that were agreed 'upon.
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Properties of the proposed backfill were provided for review. It is planned to use a mixture of sand, cement, and fly ash. The commercial name of this product is "K-Krete" (Attachment 6).
The next FSAR revision will docuent the design for the reinstalled piping, properties of the backfill material, and the stress samary table. This item is closed.
3 8 5.
Plant control restricting placament of heavy loads over buried piping and conduits
' Technical specification propost.1 by applicant for long-term settlement and strain monitoring plan during plant operatiori These are technical specification items. The information will be provided to the NRC as part of the. FSAR technical specification submittal.
4.
FSAR documentation on as-built condicions This is a confirmatory item with all technical issues resolved. The inf6tuation will be provided to the NRC l
once the appropriate construction stage is acheived.
Diesel Generator Buildino Analysis 1.
Resolution of assaptions *(structural rigidity) and completion of analysis that uses correct settlement values; occumentation of these results with comparison to recorded and predicted settlements The NRC staff reviewed calculations for the diesel gener-ator building which included settlement effects prior to, during, and after surcharge, including predicted values for the life of the plant.
The maximum calculated stress for the period March 28, 1978, to August 18, 1978, is approximately 11 ksi.
The NRC staff expressed the need-to further review the results of calculations on the effects of settlement on the DGB. including the method used by the applicant to characteri:e the shape of the structure resulting from actually recorded settlements and predicted settlement values.
Bearing pressures were reviewed and found to be acceptable.
2.
Long-term settlement monitoring plan during plant operation.
This is a technical specification item. The information will be provided to the NRC as part of the FSAR technical specification submittal.
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Permanent Dewatering 1.
Resolve availability of 60-day period in view of recharge rate in wells in A8 railroad bay area The applicant reviewed with the NRC staff the events related to the ruptura of a construction water pipe which affected the recharge response in the railroad bay area.
Information in response to written questions by NRC Hydraulic Engineering Section were provided for future review in Bethesda and included information on the period to initiate shutdown. This period will be doctshanted in the technical specifications.
'A report will be submitted after system installation to document the water contours developed by the permanent dewatering system. This report will provide verification of any water source in the railroad bay area.
2.
Requirements of permanent dewatering system during plant operation This is a technical' specification item. The infonnation will be provided to the NRC as part of the FSAR technical specification submittal.
3.
Results of typical well fines monitoring The soplicant provided typical results from the July fines monitoring of the AB construction dewatering wells.
Well 5 micron (com) 50 inicron (comi ME-7 0.5 t). 2 ME-8 1.1
- 0. 4
.i HE-9 0.5 0.3 i
ME-46 0.6
- 1. 0 This item is closed.
Other items A presentation was given on the project organization and consultants for the soils work (Attachment 5).
]L he r Darl S. HoodT7roject Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
1 As stated cc: See next page
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ENCLOSURE 1 Midland Audit
+
Attendees 7/27/82 i
NAME ORGANIZATION James K. Meisenheimer CPCo.
T. R. Thiruvengadam CPCo.
K. Razdan CPCo.
J. A. Mooney CPCo.
Jo;m Schaub CP.Co.
Bill Cloutier CPCo.
Der.nis Budzik CPCo.
N. Ramanujam CPCo.
Frank Rinaldi NRR:0L:SE3 Darl Hood NRR:DL:L3 #4 Joseph Kane NRR:DE:HGE3 NRC: Geotechnigal Steve J. Paulos Engineers, Inc.
~
Pao C. Huang NRC Consultant Gunnar Harstead NRC Consultant John P. Matra Jr.
NRC Consultant Hari N. Singh U.S. Corps of Engineers Chicago R2be Samuels GEI/Crimmins Samuels Edmund M. Burke MRJD (Bechtel Consultant)
Neal Swanberg Bechtel Gordon Tuvesea Bechtel
- 8. Dhar Bechtel John E. Anderson Bechtel S. S. Afifi Bechtel S. J. Rys Bechtel V. Veyma Bechtel M. Dasgupta Bechtet N. Rawson Bethtel
- j T. Dabrowiak Bechtel D. Reeves Bechtel C. Knifton Bechtel li R. Tulloch Bechtel R. L. Rixford (Part time)
Bechtel L&S L. McElwoo (Part time)
Bechtel M. Henry Bechtel P. H. Stravbe Bechtel Bechtel B. Klein
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ENCLOSURE 1 (Con't) l Midland Audit Attendees 7/28/82 4
NAME ORGANIZATION James K. Meisenheimer CPCo.
T. R. Thiruvengadam CPCo.
K. Razdan CPCo.
J. A. Mooney CPCo.
John Schaub CPCo.
Bill Cloutier CPCo.
Dennis Budzik CPCo.
D. F. Rank CPCo.
N. Ramanujam CPCo.
Darl Hood NRR:DL:LB #4 Joseph Kane NRR:DE:HGES Lyman Heller NRR/HGES c
Steve J. Poulos NRC: Geotechnigal Engineers, Inc.
Gunnar Harstead NRC Consultant John P. Matra Jr.
NRC Consultant Rube Samuels GEI/Crimmins Samuels Neal Swanberg Bechtel B. Dhar Bechtel John E. Anderson Bechtel S. S. Afifi Bechtel V. Verma Bechtel T. Dabrowiak Bechtel O. Reeves Bechtel 1
D. F. Lewis Bechtel
~
Chuck Russell Bechtel Larry Young Bechtel David Griffith Bechtel D. A. Zanese Bechtel W. Paul Chen ETEC
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ENCLOSURE 1 (Con't)
Midland Audit Attendees 7/29/82 NAME ORGANIZATION John Schaub CPCo.
N. Ramanujam CPCo.
J. P. Knight NRR Darl Hood NRR:DL:LB #4 Joseph Kane NRR:DE:i!GES Steve J. Poulos NRC: Geotechnigal Engineers, Inc.
Gunnar Harstead NRC Consultant John P. Matra Jr.
NRC Consultant Pao C. Huang NRC Consultant Rube Samuels GE!/Cr.msins Samuels Neal Swanberg Bechte.
B. Dhar Bechtc1 John E. Anderson Bechte'.
- 5. 5. Afif t.
Bechtc1 D. A. Zanese Bechte:
T. T. Tseng Bechtti t
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7/ n/ s o - Open item CON - Confirmatory item TS - Operating I.icense Technical Specificalinn N - Teclinical Resolut ion Staf f Isiput l'eniling C - Closcal Item tillll.ANil l'I. ANTS IINIT I AND 2
.REYlkki b hb N I5.[ OEfl.EllENT NO 2 SSER AlinlT STATilS ITEH CENERAI. ITEllS I.
Staff's input for the final SSER will inclusic summary of subsurface R
No investigations.
2.
Staff's input icio final SSER will describe latsoratory anil fielst testing.
R No 3.
Staff's input inta the final SSER will incluele ataff evaluation of pertinent R
No soit profiles sectional views.
4.
Summerize the setticment history of Category I st ructures other than the R
No All T. SitPS.
5.
i.ong term settlement monitoring -plans aturing plant operatina for othc.r TS
.No structures.
+
6.
HRC's input into the final SSER will cover range of applical hearing pressures R
Yes statir anIelynamic lomiting.
l 7.
Applicasit was reignest e I to eletermaine Ilia t 1.5 x l'SAR scismic resposise spect ra CON Yes I
analyses are cosiservat ive for the musiliary insililing, SUPS, anel llW'iT in j
comparison to, site specific response spertra.
8.
Applicant has not provisteel comparat ive plot s of floor s csponse resguestest 0
Yes by the staf f for all Inollilings (seismic margin review).
mio781-0048aI68
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Resolution of allowable vertical differential settlement and strain that 0
Yes will stop esenlerpinning const a ntt ien asiel reepsire installation of temporary supports.
2.
Caempartion control specification for grann'lar fill 1.csiesth FIVP's.
0 Yes j
3.
Methodology for transferring final loa.Is to permaneset nederpinning wa'l.
0 Yes 4..
Ba dated scope of const ruction for 1%ses 3 acid 4.
0 Yes' r
5.
Ilesolution of pier assessfhseshed test ele tails on maniense test load, locations
~
0 Yes j,
ased time for periosasing test.
ii.
I.ang term settlement anel st rain sunnitoring Islam during plant operation.
TS Yes i
)*
7.
FSAR documentation on as-huilt conditions.
Call go.
8.
Design anodification at freezewall crossing with duct banks.
Call llo-i 9.
Resolut ion of reeguired depths of const riert ion alcuat ering wells.
C0li Yes i
i 10.
Bloeiltering matrix showing allowalile set tlement s and strains cost Yes lj II.
EPA ased CT relative horizontal suavement criteria C000 Yes-
+
- j 12.
Changes in pier coniiguration Coli Yes ll 13.
Details on stif fencel lenthhead during etritt excavation Cool Yes
- i 4
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- 14. As lueilt plan for deep seated leenclunarks Call Yes e
i 15.
Iteview of einergesecy actions C-200 C00f Yes I.
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T SSER AlllllT ST_AT_il.S.
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EEEY!CE 1ATEMM,N',,gTN{N'Tlyg l.
Complete Staf f review of slidiseg anel lateral s.wil pressure calrielations C006 Yes under elynamic loading.
2.
Resointion of pier anil plate inad test details on anaximeun test loail, locations, Call Yes and time for performing test.
3.
Resolution of reignised depths of constiiertinsi dewatering wells.
0 Yes 4.'
Hethodology for tras sferring laaels f rene Jacks to permanent wall and locking-of f.
0 Yes 5.
l.ong term settlement and strain munnitoring plan durin5 plant operation and TS Yes program for monitoring horizontal movement.
I 6.
FSAR documentation on as-huilt renelitions.
CON No 6a.
Strain monitoring to measiere acceptable allowahle. strain.
Coli Yes 7.
Staff's input f eito final SSER will elescrilie computed can th pressures under R
Yes l.oth static anit.lynamic leading an.1 desisse metho.Is.
S.
Staf f to review anel evalisate Applicant's analysis as islent i fical ! response C0li Yes to Resinest 2.8 nf Enclosure 8, NRC let ter elateil 5/25/82.
(leiteraction of riac water 5 SWPS walk)
' 9.
Check dowels for slocar and tension rap.ileility.
CON Yes l
4 4
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min /42-0045aI68 f
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_I_T_ F_J.i.
h00 TATER WATER STOIIATE TANK I.
I.ang term settlement monitoring plan during plant operatiosi.
TS No 2.
FSAN deciementation on as-biellt conditions.
CGIl lio 3.
Staf f calculational review for gaverning Inading camleinat ions in structural Call Yes design.
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1.
Staff's evaluation of previously suhaitte. reports on undergrosend piping R
Yes not completed.
)
2.
Applicant's proposcel reinstallation of 26-inch 36-inch ellameter pipes including 0
Yes review of analysis, properties est bacitfill, exteest of, excavation sletails of t ransitiese, controls sharing const raect ion.
i 3.
Plaset control restricting placcenent of heavy loads over bearini piping and TS No cosedesi L s.
4.
FSAR decaementation on'as-built conditinns.
C011 No 5.
Tech Spec proposal ley Applicaest for long term settlement and strain monitoring TS Ne plan during plant operation.
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SSER AISIT STA.T.il.S ITDI III,ESEI. GEllERATolt RIlifJIING ANAI.VSIS I.
Nesointion of assumptions (structural riglelity)anst ensepletion of analysis' 0
Yes that uses entreet settlement values. Ikwumentation of these results with comparison la recareleet anel preilictcal set t lemen.ts.
2.
Imag tese settlement smanitoring plan eluring plant operation.
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Nesolve availaleility of 60 day 3.crin.l in view of rerharge rate in wells l'a
'O Yes railroad hay arca of Ansiliary Neeililing.
2.
Respairements on ticomanent Jewatering system elaring plant operatina.
TS no 3.
Results of typical wcIl fines muniitoring Coli Yes,
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it e, Om Meetinz Notes for NRC Audit of Soils Remedial Activities
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Held July 27-30, 1982.
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s Bochtal Associatcs Professional Corporation 777 East Eisenhower Parkway Ann Arbor, Michsgen anonasewee. P.O. Sor 1000. Ann Atoor. Micrugan 44106
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BLC-M Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Attention Mr. 1.C. Rauman Design Production Manager
Subject:
P.idland Plant l'aits 1 and 2 Consumers Power Company Bechtel Job 7220 Meeting Notes No. M -
Meeting Notes No. W for the !.1tC audit of the er:; f.s r c ~ e i / a *.
ln
.t st.-._._. * *p'--' : Mid M i tir f '", 1;02, are s.ttached
.h for your information and use.
Y ' ' ~ :' l '/J J Very truly yours, A. _.J 7
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E.M. Hughes Ann Arbor Project Engineer NS/cs 3/25/12
Attachment:
Meeting Notes No. 29P2_
cc (all w/a):
bec (all w/a):
D.B. Miller B. Dhar T.J. Sullivan D. Ta11gres R.A. Wells T. Johnson D. Lewis k 3004
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7-6.
NRC's input into the final SSER will cover ratge of applied bearing pressures s static anc.' dynamic loading.
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p Applicant was requested to determine that 1.5 x FSAR seismic response spectra 7.
analyses are conservative for the auxiliary building, SVPS, and BWST in comparison to site specific response spectra.
[b 4. Nbd ln.
7 4 W C ol te
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.s l re bu r e.
And hseale=
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8.
Applicant has not provided. ecmparative plots cf floor response requested by the staff for all buildings (seismic margin review).
b o e, p a e < b,*s e p lC
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- p. Test data on #9 and #10 Fox Nowlett with up to 2*. strain. -
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4 W ew e-
- n. Identification, inspection and repair procedures for concrete crack repair.
febe sch-e s -for coNcAEAc ~bo l' y r<e.
e.g, e H e m se, n 4.t in c
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a n.t a,e H..D en.f m. A s f e.).
? % $ 1-l!kl/839/
l l
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y w
A L/X o f.1 A. R y B uit.biM& '
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. Resolution of allowable vertical differential settlement and strain that will stop underpinning construction and require installation of temporary supports u em,
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Prwl Le.s. d e[ln adisns ? I a /er,
/
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. a n d ' cec.? ton levels v h eh w e< e a :, e.< L yan fo e W
..u n d.e e p in n, ng cr. h Adr.<.i. A H.rek ca e
n u m e < re s,. ( o f u n f v S.p rorc h.s et g,;e s d upon duern 5 7
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2.
Compaction control specification for granular fill beneath FIVP's ft vn.s nc<a.I lb-l fhe f:lI hene /f +he FIvP u; ll
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}he Se,L<aa K Fsht. A copy s$}hc
/ h i.s Fs A t s <J,os m., pr ad e J by + A c yirs n oS Yhe $. lI M*Ilhe n o r, p la.> -li'c.. 7"his The fin.s podto.Ned e
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_... u r f h The bee.x h II u,II b e. p e,p.e<ly in o is 4 ~ r e c on d: />on e J by m
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3.
Methodology for transferring final loads to permanent underpinning vall.'
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s.iilI be RPProsed by
< n e.m n s e ny (*1 C < <~,
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Updated scope of construction for Phases 3 and 4.
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'5.
. nd time for performing test. Resolution of pier and plate load test d 3
a mum test load, locations
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6.
Long tern settlement - '
sonitoring plan during plant operation.
b SShA A l' Gab c,.
P t e-O n*
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rne.in de fhe 's cifl<~~ / n on !=rb s Pr*s r*m L *n5 p la a 4 op em b ro e,
.8.
Design modification at freezewall crossing with duct banks.
Can.s N e r s. vl.A.I. f r b e i d e r*
- Po r-l'
- = d' M.s in p sls cc - -t w u.u.+c a p.u ua
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4.
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b 9.
Resolution of required depths of construction dewatering wells.
T b c d -p / h.s o/ conde-elion a l e, ins w e //.s
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in in cohe.a. l c n<%< l on R IQ.so;l.s,<n e xcunbe _. m ap nin e l._.2 f.e.ef b8o,v.a hva / e/ vi l( es s e
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at.
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3) 10.
Monitoring matrix showing allowable settlements and strains w+
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e << h ar el A c.kfa la s e /.s u.IIbe aeded l
a p r <<d u un C s e.e.
a ' a la. y k. - /.t.a.S den /
a.s u
11.
EPA and CT relative horizontal movement criteria
'/~};e
/V'l d 5 [n. 'f(.
o-C.er e w e d Je hd b k ?-een M e c}rse i,sp.s sbsw.ns. +h<_
5
nn b e r e.c,,.te d _ foc ca l e n, h a, O +- >c.=., ~ 12. Changes in pier configuration Precs 6 7'1'x an.I.l C 7' 7,c la ha/e d olr~J Ke a 'd-re0 a r< e J.. en k_/ h e reld er n d 7.,,2. 4<,* l n e r e J. P, e,.s 5. or/ Al enJ K ca,* I.he . h'x <n s cL/n</M,,,,,, s h C.f re. r< w e J. As a,# / h es Th< blA c i s . s 4, w,,,, hne d.e/a:/.s o e p,'e r.s. d.wa., s s 13. Details on stiffened bulkhead during drift excavation . IL NRc s.b..ff.e e < <eJ wi~th Lh e ele-f+/. d (f'.,e ) c bu /kkee J desy n.. 7~1 eW, /60- t ees,,,,n e n de d fhd o-f ca.s k,,e},w 1,e e./t.,,,m / ad a,,.I im/ be I k b eec. k <. con s fru / e d _ in A Rs + i,, ce<m e d,,-{+ p.1 o on +he l l-h e ~ hh et. ben t.h e cl S loP e on 'fh e };~ W' S,-de., 4)s 14. As built plan for deep seated benchmarks 'W. The.. W /{ 6. 5 Y $. Y' 4 v tT. * ' < ti.... a.c.1 u,- // /ou A.>,,. deaa.h.4 C-/4 zo.e n4.c-1Mi .s A oo, n, an,cire >,- I.t,,, d.<ep.se-/<et o a., c f,,, t; o f l-A < ~ - a d.:g :. 'I L m~1'<G< =,c / . / /.r
- r i.
.L, fe. /., f j o _'...<<.w s ;. a. -m . t r, or r. v.:. ,,i_ ,,, u s , Wen cn f. 4lC) u s< J u.o -- - l ll ej ~ ~..,, c I b? .?:
- 15. Review of emergency actions C-200 i
7 The f/ow c b,J.s a/ spea6c</,,,n c.no ve<e r-e-r<a ea in d a. /- I. Th er e no op en ri em -- /_*. ', e % ~-- I. w= L '.,., [ _.!3.!. :: n [ l. ~ a -i. .-...y ,r., v SERVICE WATER PUMP STRUCTURh; 1. Complete Staff review of sliding and lateral soil pressure calculations under dynamic loading. The h1RQ. s e 5 cm k < U < c<rm d +h ' sIrd.ng end /e m I.sai Ipr e.s.s-c.o cs /c L un.s. __.__.. A ll f u 4.s lfon.n W 4ec.. fCso k.C..N... i 1 i %+ 6 _y ~ - -.... _....... _......... o // { '- j l C& Y~Y r + y i 2. Resolution of pier and plate load test details on maximum test load, locations, and time for performing test. 4......_ksf M ! I b e.--.P fr.. ' '
- c d' Ge I 9
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--. Pisc.)h. (udsr0 T h e ] o a.f.s e p / &
ne
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to 75%
ho
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.... =
3.
Resolution of recuired depths of construction devatering wells.
For construction devatering at the SiiPS, 12 pie:eneters win be provided. Six vin be sealed in the zone from Elevation 570' to Elevation 590'.
Soil sa=pling vill be con-tinuous.* rom Elevation 570' to Elevation 585'.
The other six vin be installed at the sub-contractor's discretion.
The water surface vill be maintained 2-feet belev the excavation if sand is present. An.
~ ~
vens vill be lowered to Elevation 570' or exploratory information from the six deep
..- ~ ~ " " _.
piezo=eters win be provided to deter =ine the
~ ~ ~ ~ ~ -
existance of sand layers. If sand layers are identified by the pie ometer installation, the wells will be lowerad.
W._. 4.
~
Methodology for transferring loads from jacks to permanent vall. and locking-off.
san.n L (_lo..!l....e4,na G t 5.,,1c <-,- o. e w e.!... d<a,ry C-2037. A w.'h b c NN. :. bf/
_ A. B.. p esk w e c.
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4--
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train.
Strain monitoring to measure eccgptable allcwsb e s 6a.
7.
Staff's input into final SSER will describe computed earth pressures under both static and dynamic loading and design methods.
~
~
Re%u A cGkTe~i.'~&M p:e.ssarke o-n plcl. eel, 4-//
, edans v e< e eeu lve c
8.
Staff to review and evaluate Applicant's analysis as identified in response to Request 2.8 of Enclosure 8, NRC letter dated 5/25/82.
(interaction of cire water & SWPS wal4)
The. //A C slN$
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l-n
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is c,,o s c.% d w,,Me.Ae ex,nl<.t.r,s - e.,k ae,aph,6te_.to a
3P 9.
Check dowels for shear. and tension capability..
t
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S 4
I 1
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BORATED WATER STORAGE TANK 3.
Staff calculational review for governing loading combinations in structural design.
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e, /c.
le The WRc.ila..
isn.fo, fon&An'. Th<
d e.> rp n O6
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=
i
+
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.n
' jy Y W DS f & Ot/h(D
? / ? / $ (,e 3.
Staff's evaluation of previously submitted reports on underground piping not completed.
77)e. /v'Ac' s l.hf rese e[i, dep+h ca fe-lif ions for L
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7Ac fEDn1 In* kNs Osy,
.5 but. f Qpreed.4s?Tfh hhe R $> 5 s< sn f If.$__ &k hb&
R A at fy'$/3 9.A ye s s,.
2.
Applicanc's proposed reinstallation of 26-inch 3.6-inch diameter pipes including review of analysis, properties of backfill, extent of excavation details of transitiqn, controls during construction.
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t s en.,ic. c_ w / e,- ( m i m> n s
< e A e ved
- c. n d c:. p,:< ~ e J.
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DIESEI, GENERATOR BUII. DING ANAIYSIS 1.
Resolution of assumptions (structural rigidity)and completion of analysis t,
that uses correct settlement values. Documentation of these results with comparison to recorded and predicted settlements.
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- 8.
____-__-___-_____.___-______m.
Qt vg PERMANENT DEWATERING i
1.
Resolve availability of 60 day period in view of recharge rate in wells in
-railroad bay area of Auxiliary Building.
ThcNpp'burb.l.a.jaye.Iu;__k_bf^eeeen q. r o l' et WRc plcW lhe ch
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I O - Open item CON - Con f i rma to ry i t em TS - Operating License Technical Specification R - Technical Resolutio: Staff input Peniling C - Closed item 4
HIDI.AND Pl. ANTS ilNIT I AND 2 i
REVIEW OF DRAFT SER, SilPPl.EilENT NO 2 6
SSER AUDIT STATilS ITEM
.I q
CENEMAI. ITEilS I.
Staf f's input for the final SSER will include summary of subsurface R
No investigations.
3:
2.
Staff's input into final SSER will describe laboratory and fielet testing.
R No 3.
Staff's input into the final SSER will include staff evaluation of pertinent R
No soll profiles sectional views.
i 4.
Summerize the settlement history of Catagory I structures other than the R
No AR & SWPS.
5.
I.ong term settlement monitoring plans during plant operation for other TS No i
structures.
4
{
6.
NRC's input into the final SSER will cover range of applied hearing pressures R
Yes l
static and dynamic loading.
7.
Applicant was requested to determine that I.5 x FSAR seismic response spectra CON'4C Yes analyses are conservative for the auxiliary building, SWPS, and BWST in comparison to site specific respos;se spectra.
8.
Applicant has not provided conip,arative plots of floor response requested
& C-Yes by the staff for all buildings (seismic margin review).
min 182-0048aI68 I
4 SSER AUDIT STATUS ITEN 9.
Test data on #9 and #10 Fox llowlett witti up to 2% strain.
. CON C Yes 10.
Identification, inspection and reglair procedures for concrete crack repair.
10N &
Yes i*
J:. !!:: f ::::: L apitisiliii'ancirsre-le-attacle--piping end-egtripment-to inemenry,
i, L
i maril; 5: die iiowco py ataii s i ii. ?e-(aonssotis.W pp ' M Staff's input into time final SSER will summarize geoteclusical engineering R
No review efforts and SilAKE computer code studies.
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SSER ALIDIT STATilS ITEN AllXil.l ARY hilli. DING I.
Resolution of allowable vertical dif ferential settlement an.I'st ra'in that 40 Yes will stop underpinning construction and require installation of temporary supports.
2.
Compaction control specification for granular fill beneath FIVP's.
XC Yes i
3.
Hethodology for transferring final loads to permanent underpinning wall.
WC Yes 4.
lipdated scope of construction for Phases 3 and 4.
- C-Yes i
5.
Resolution of pier anil plate load test details on maximum test load, locations WC Yes and time for performing test.
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6.
Long term settlement
" ^ :M monitosing plan during plant oper: tion.
TS Yes 5
yj 7.
FSAR documentation on as-huilt conditions.
CON No -
1
---]> 8. Design modification at freezewall crossing with duct leanks.
CON No l
9.
Resolution of required depths of construction dewatering wells.
Self"C Yes i
10.
Honitoring matrix showing allowalite settlements and st rains W C Yes i
11.
EPA and CT relative horizontal movement criteria Gelt c.
Yes i
12.
Changes in pier configuration EON C Yes 13.
Details on stiffened hulkhead during drift excavation EON C.
Yes 3
- 14. As built plan for' deep seated benchmarks delf* &
Yes 4
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15.
Review of emergency actions 0-200 CON-C Yes I,
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l melH182-004Ra168 1
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~
STATUS lYEH SERVICE WATER PUHP STRUCTilRE i
1.
Complete Staff review of sliding and lateral soil pressure calculations Celf C, Yes under dynamic loading.
2.
Resolution of pier and plate load test details on maximes test load, locations, GelFC Yes and time for performing test.
3.
Resolution of required depths of construction dewatering wells.
4"(
Yes
[
4.
Hethodology for transferring loads f rom Jacks to permanent wall and locking-of f.
-G C Yes 5.
Long term settlement an rir in monitoring plan durisig plant operation,and TS Yes d
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6.
FSAR documentation on as-built conditions.
CON No 6a.
Strain monitoring to measure acceptable allowahic strain.
4;ett-C -
Yes
.i 7.
Staff's input into final SSER will describe computed earth pressures under
.R G Yes both static and dynamic loading and design methods.
1 1
l 8.
Staff to review and evaluate Applicant's analysis as identified in response felt C, Yes to Request 2.8 of Enclosure 8, NRC letter dated 5/25/82.
(interaction of cire water & SWPS wal$)
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9.
Check dowels for shear and tension capability.
GON C' Yes 1
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?
-SSER AUDIT.
STATUS ETEN R. OR.AT.ED WAT.ER STORAGE T_A_NK.
l.
I.ong tern settlement monitoring plan during plant operation.
TS No 2.
FSAR documentation on as-built conditions.
CON No 3.
Staff calculational review for governing loading comleinations l'n structural eelP C-Yes design.
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STATUS.
ITEN.
4 i'
IINDERGRollND PIPING 1.
Staf f's evaluation of previously sulaitteil reports on underground piping
- (-
Yes not completed.
2.
Applicant's proposed reinstallation of 26-inch 36-inch diameter pipes including MFC Tes review of analysis, properties of backfill, extent of excavation details of i
transition, controls during construction.
3.
Plant control restricting placement of heavy loads over buried piping and
-TS No 8
conduits.
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4.
FSAR documentation on as-built conditions.
CON -
No i.
j 5.
Tech Spec proposal by Applicant for long term settlement and strain monitoring TS No plan during plant operation.
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STATUS' ITEN -
1 DIESEL. GENERATOR Billt. DING ANAI.YSIS I.
Resoliition of assumptions (structural rigidity)anil completion of analysis 4r6 Yes that uses correct settlement values. Docismentation of these results with comparison to recorded and predicted settlements.
2.
l.ong term settlement monitoring plan during plant operation.
TS No I
1-1
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STATUS ITEM l'fiRHANENT DEWATERING 4
9 I.
Resolve availability of 60 day period in view of recharge rate in wells in 0
Yes railroad hay area of Auxiliary Building.
2.
Requirements on permanent dewatering system during plant operation.
TS No 3.
Results of typical well finc.s monitoring eerC Yes
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min 182-0048aI68 4
e
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- n.s..e e., f Alert Level
+
All values up to the alert level are considered to be within normal working ranges.
Settlement readings should be reviewed by the resident structural engineer daily. In general, for readings below the alert level, attention should be focused on the value of the readings versus the 2
construction progress and-any indication of trends that would indicate the alert level vill be exceeded.
Once the alert level is exceeded, the site resident engineer must inform l
engineering in Ann Arbor of the situation. The data including information from the other appropriate data mechanisms should be evaluated in total. Where trends exist that indicate the action level is 4
likely to be reached, plans,should be evaluated to remedy the situati,n.
(Note: It is recognized that the evaluation may well conclude that no changes are warranted.)
(
Action Levels
- i Yalues in excess of the action level must be reviewed by the resident structural engineer and as soon as possible by engineering in Ann Arbor.
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Plans should be initiated to modify-the condition that caused the settlement reading to exceed the action level. Consumers Power Company must be informed of the revised plan so that the NRC can be advised of the situation. The revised plan shall be initiated immediately upon verbal notification by the resident structural engineer. (Note: It is recognized that the evaluation may well conclude that no changes are warranted.) If continuous movement beyond action level occurs, immediate action shall be taken per Specification C-200.
- - Cracking levels correspond to these definitions for Alert and Action.
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