ML20114D357

Interim Deficiency Rept Re Diesel Fuel Oil Tank Soils Borings.Initially Reported on 841121.No Corrective Actions Necessary Due to Present Project Shutdown

ML20114D357
Person / Time
Site:	Midland
Issue date:	12/21/1984
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
32097, 84-17-#1, NUDOCS 8501310231
Download: ML20114D357 (5)

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ff y0lP . IGA co0sumers q= q Power 5PnD James W Cook OOlUQl0Y FIL W Vice President - Projects, Engineering and Construction oeneral offices: 1945 West Parnali Road, Jackson, MI 49201 . (517) 788-0453 December 21, 1984 84-17 #1 Mr J G Keppler, Regional Administrator US Nuclear Regulatory "-- '- '--

Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 DIESEL FUEL OIL TANK SOILS BORINGS FILE: 0.4.9.104 SERIAL: 32097

References:

1) Letter, R J Erhardt to H R Denton, Serial 32090, dated November 21, 1984

2) Letter, J E Brunner to ASLB Members, dated December 6, 1984

3) Letter, J A Mooney to H R Denton, Serial 16881, dated May 3, 1982 On November 21, 1984, Consumers Power Company (CP Co) notified your staff of a reportable condition concerning records of soils Borings B-1, B-2, B-3 and B-4. References 1 and 2 provided additional information on this subject.

Pending resolution of our request to waive the requirement to submit a written 30-day 50.55(e) report during the project shutdown, we have prepared this interim report on the above subject.

Description of Concern It has been determined that the data for Borings B-1, B-2, B-3 and B-4 submitted to the NRC by references 3 and 4, presented in the Midland FSAR and in the response to 50.54(f) questions, do not represent the actual borings which were taken at the diesel generator fuel oil tank location.

Reference 2 is attached to provide a description of the situation and the concern raised as to the potential effect on analysis of liquefaction potential of the soils beneath the diesel fuel oil tanks.

Safety Impact The sole technical issue potentially atr'ected by the invalidity of the previously submitted boring logs B-1 through B-4 relates to the potential i 4 22 OC1284-0505A-MP02 h1h0 s

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2 Serial 32097:

84 #1 M liquefaction of the sand. layer between elevations 600.5' and 603' indicated in-boring DF-5. It is our conclusion based on a conservative assessment of available information that the analysis of'the liquefaction potential of the

soils beneath the diesel fuel oil' tanks is inconclusive.

Root Cause It appears that a comb'ination of' events occurred which allowed the use of ~

incorrect boring logs. ,

1. 'In June and July of 1977 respectively, the same company'(Raymond) made the actual diesel fuel oil tank' borings and the borings which were erroneously  :

submitted. The borings which were mistakenly submitted related to an AT&T 1 Project in Midland County that had no relationship to Bechtel or Consumers 4 Power Company. The actual B-1 through B-4 borings at the Midland jobsite

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were taken to obtain soil samples at the proposed location of the diesel

) fuel oil tanks.

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2. Both boring series were labeled B-1 through B-4 and the soil types, boring

, depths and taking of Shelby tube samples for the AT&T borings were, in

[ general, similar to other borings taken at the Midland site. The AT&T l . borings listed the job address as Midland, Michigan.

3. During the Site-wide soils investigation in the spring of 1979, it was

! determined that boring data was required in the area of the diesel

{ generator fuel oil tanks. :Bechtel personnel.then recalled-that borings I had been made there in the summer of 1977. The Bechtel Geotechnical

. Engineering Group (Geotech), which was not involved in the 1977 borings, asked Project Engineering to provide the boring logs. Project Engineering i- believed that no drilling logs had been made for the B-1 through B-4 borings at the Midland Site. However, their response to Geotech apparently did not clearly convey this but rather it was understood by Geotech that l j Project Engineering didn't have any' logs and not that they didn't exist.

j Bechtel speculates'that the handwritten drilling logs taken for the AT&T j project may have been supplied by the drilling contractor-(Raymond) in .

response to a request-by Geotech for logs of the B-1 through B-4 borings.  !

taken at the Midland jobsite.

F 4. In March of-1982 the handwritten B-1 through B-4 drilling' logs again surfaced in conjunction with the design of the site dewatering system,

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j r- The recent Bechtel investigation indicates that one Bechtel employee believed that the handwritten driller's logs:did not record borings taken  !

l in the area of the diesel fuel oil storage tanks and that there may.have been discussions within'Bechtel's Geotech group on this matter. 'Apparently ,

, a decision was made based on~the available data to. include these driller's

j. logs as input to the liquefaction analysis for'the buried diesel' fuel _ oil

tanks. _ Subsequently, Consumers Power submitted the handwritten driller's logs to NRC informally andLthen via reference 3.

5. Bechte1~ prepared typewritten boring logs from the handwritten driller's logs for. inclusion in'the-June 1982 FSAR submittal.- This' limited further-

! opportunity to detect from the original driller's logs that they were incorrect i

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'3; 1 Serial 32097-

< '84-17':#1 as to the Midland site location'aince-the original driller's logs were now back in.the: files. The typed boringLlog profiles include additional information

, which is believed to have been obtained from the-test records of the borings

'actually taken at the : Midland -jobsite, such as the boring coordinates. .

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, It is= normal practice for'aLhandwr'itten boring log to b'e produced at the time =

a boring is made. These logs are produced by the technical person' overseeing i the drilling operation. Information concerning boring locations is entered

. in:.the logs by such technical ~ personnel', and thus-can be directly traced to-

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l the. Midland jobsite. In the case of Borings B-1 through B-4, the erroneous >

logs (ie, the logs of the AT&T borings) contained no location coordinates.or

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other informationLdirectly indicating the. location of the borings. Instead, the. location information obtained from tasting-data concerning the onsite B-1  :

through 5-4 borings was assumed to be applicable to'the. logs of the offsite

< boringsa As previously stated, this confusion resulted in. logs of.the incorrect borings being submitted to the NRC.. The absence of location information on the drilling logs traceable to the Midland site is a circumstance unique to Borings B.-l'through'B-4.

I A review of all Bechtel borings incude'd in Section D.1.4 of the Soils 50.54(f) response in'icates d that borings B-1 through B-4.'are the only borings-l made from a driller's log. All.the other borings.were produced from 4 handwritten boring logs by a Bechtel Geotechnical Engineer assigned to the drilling. The normal practice of involvement by Geotech personnel would j preclude any generic repetition of the unique circumstances of this l particular situation.

I Corrective Action i

! The controls in place at the time of the Project shutdown were adequate to

. prevent a recurrence of this problem, thus no process corrective action is

necessary.

i l Part corrective action required includes correcting the affected documentation

and determining if additional analysis or additional field information is i

necessary to address the issue of potential liquefaction of' soils below the l diesel fuel oil tanks.

l Because of. the Project shutdown, these corrective actions will not be pursued and no further rerorts on this subject will be made unless the Midland Energy

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, Center is reactivated. This item will be. entered ~in our Correspondence ~and4 Commitment Manag ement System for long-term tracking.

.j f 'JWC/JLW/ksa-i I CC: Document Control Desk, NRC EAdensam, NRC Office of-NRR; j

{ Washington, DC Bethesda,' MD '

INPO Records Center '

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Serial:32097 84-17D #1 'l

, , l OM/OL SERVICE LIST JMr Frank'J.Kelley _ Atomic Safety'& Licensing '

Attorney General:of:the Appeal Board-State of Michigan U S Nuclear Regulatory Commission

'Ms Carole Steinberg Washington, DC-20555c

" Assistant Attorney Generall Environmental Protection Division :Mr C RlStephens (3)

.720 Law Building Chief, Docketing'& Services

. Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the: Secretary Washington', - DC . 20555

. Mr Myron M Cherry, Esq Suite 3700 . Ms Mary Sinclair

.Three First National Plaza. -5711 Summerset Street j ' Chicago,;IL 60602 -Midland,-MI 48640~

i. Mr Wendell H Marshall Mr. William D'Paton, Esq f

RFD 10. Counsel for the NRC-Staff Midlan'd , MI 48640 U S; Nuclear Regulatory Commission l Washington, DC 20555.-

Mr Charles-Bechhoefer, Esq Atomic Safety & Licensing . Atomic Safety & Licensing Board Panel Board Panel p U S Nuclear Regulatory Commission- U S Nuclear Regulatory: Commission l East-West Towers, Room E-413 Washington, DC 20555

, Bethesda, MD 20014.

! Ms Barbara Stamaris l Dr Frederick P Cowan 5795 North River Road:

1 6152 N Verde' Trail Rt 3

! Apt B-125 Freeland,;MI 48623 j Boca Raton, FL 33433

! Dr Jerry Harbour.

Mr Fred C Williams Atomic Safety & Licensing

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Isham, Lincoln & Beale Board Panel-i 1120 Connecticut Ave NW, Suite 840 U S Nuclear Regulatory Commission j Washington, DC 20036 -

East-West Towers', Room- E- 454 Bethesda,-MD 20014 i

Mr James E Brunner, Esq-Consumers Power Company. Mr M I Miller, Esq 212 West Michigan Avenue -Isham, Lincoln,&~Beale-F Jackson, MI 49201 Three.First National Plaza I~

52nd Floor Chicago,-IL 60602 3

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Mr Steve'Gadler,.Esq Mr John Demeester, Esq..

2120 Carter Avenue Dow Chemical Building St Paul, MN 55108 Michigan Division Midland MI 48640 Mr.P' Robert Brown Clark..Klein & Beaumont Ms Lynne'Bernabei 1600 First Federal Bldg. Government Accountability' Project

-Woodward Ave 1901 Q fereet, NW Detroit, MI 48226 Washington, DC 20009 J

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Attachment to Serial 32097 Power Campany ceneret offices: 1945 West Pernall Road, Jackson, MI 49201 + ($17) 788 0550 December 6, 1984 Dr Frederick P Cowan Ato=ic Safety & Licansing Board Panel 6152 N Verde Trail Apt B-125 Boca Raton, FL 33433 Mr Charles Bechhoefer, Esq Dr Jerry Harbour Atomic Safety & Licensing Atemic Safety & Licensing Board Panel Board Panel US Nuclear Regulatory Commission US Nuclear Regulatory Commission East-West Towers East-West Towers Room E-413 Room E-454 4350 East-West Highway 4350 East-West Highway Bethesda, MD 20014 Bethesda, MD 20014

Dear Board Members:

By copy of a letter dated November 21, 1984, from R J Erhardt to H R Denton, the Board was informed that logs "B-1 through B-4" of borings taken in 1977 in the area of the diesel fuel oil tanks at the Midland Nuclear Plant were in fact logs of borings taken elsewhere in the Midland area. Testing data indicates that a series of borings, also labeled "B-1 through B-4," was made at the diesel fuel oil tank area, but CPCo is now informed by Bechtel that the two series were confused, and data from the wrong series was transmitted to the NRC. The Applicant has reviewed the effect of this erroneous information on its technical analysis of the soils underlying the diesel fuel oil tanks and concludes that the only technical issue potentially affected is the liquefaction of soils below the diesel fuel oil tanks.

Professor Richard Woods, the Applicant's liquefaction witness, testified on November 20, 1982 concerning the potential for liquefaction of soils underlying the diesel fuel storage tanks. Professor Woods' testimony relied, in part, on an analysis of liquefaction performed by Bechtel that assumed the existence of a sand layer beneath the entire tank area, but not extending beyond the tank area, at a depth and thickness representative of information obtained from boring DF-5 caken in 1979. This boring (DF-5) is not one of the borings called into question by.recent infor=ation., Dr Woods initial

" .. analysis of liquefaction of soils beneath the tanks, which was based on a

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' review o'f Eechtel's analysis of the same subject and was performed independent OC1284-0489A-MP02 Q !}' 7 ',\ 1fr6 O

of the.information in berings B-1 through B-4, concluded that liquefaction did not pose a safety problem for the tanks. Subsequently, but prior to his

. testimony on November 20, 1982, Dr Woods reviewed the data from the records B-1 through B-4 later found to be erroneous and determined that they did not alter his previous' conclusion. 1 In presentations to the NRC 5,taff that preceded the filing of testimony, Consumers Power technical staff concluded that the sand pocket found in boring j DF-5 does not extend beyond the tank area, in part, on the basis of infor- l mation contained in the log of 1977 boring B-1 that has now been determined to be invalid. Testing data available from the B-1 through B-4 borings taken in the diesel fuel tank area indicate material acceptable for its intended Purpose at the elevations where tests were takan, -however none of the borings extend to the depth necessary to provide informction as to the actual extent of the sand pocket observed in boring DF-5. Because of these circumstances, the Applicant has determined.that the analysis of the liquefaction potential i

of the soils beneath the diesel fuel oil tanks is inconclusive.

1 Because of the shutdown of the Midland project, the Applicant does not now I j plan to perform the additional analyses er obtain additional field

information to close out this issue. We will keep the Board informed of any

! further developments on th,is matter.

• Thank you for your attention.

1 j& /

ames E Brunner 1 .

JEB/1r CC: HRDenten, NRR, Washington, DC Administrator, Region III

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NRR Project Manager, Washington, DC Kidland Project Section Chief, Region III i . .,

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