ML20126L819
| ML20126L819 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/31/1979 |
| From: | BECHTEL GROUP, INC., EECBECHA |
| To: | |
| Shared Package | |
| ML20126L803 | List: |
| References | |
| 7220, NUDOCS 8106090636 | |
| Download: ML20126L819 (22) | |
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I CLL'TD UNCS i & 2 JC3 No. 7220 4
RZ7IN OF U.S. p.,sTIyc N AND LL',0RATORT CONST200T!CN
- TIST CAIA ON SCII.S USED AS .m1
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-3E. aza Assne 1- e y p m N CCPJORA !cg July 1979 t .
810 6 0 90 {p 3($
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TABL2 0F CONTETT3 I
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- 1. Use of Laborato:7 !ast Contpaccios Cu: res 1
- 2. Quascionshia Racasts 2
- 3. Theoracically Impossible Test Rasui:s 2
- 4. Raye.acad usa of Quastionable Laborato:7 ,Tesc Caca 3
- 5. L1=1:s of Accuracy and Acespeah111:7 for Tase Data 3
- 6. Accuracy of Tast Iquipment 5 i 7. Relacive Dansity *ases 5
- 8. , Sustmary 6 TA3LZ A - Lis:1:g of all classifica:1 cts rafaraccad 1: Plan: A:aa Fill Soil *ast Raceris which vers used for 20 or : ora Fiald Consi:7 Tes:s.
!AILZ 3 - Notas on Questicuable Cleari=g of 7 ailed Tas.:s. ,
't TA3LZ C - Notas Ralacive :o Questicuable Test Ta:a MGU2Z 1 - Moisture tensity for 3MP 278 - All Tests 7:GUZZ 2 - Moistura Cansi:7 for 3M 278 - Passi:g Tas:s Cnly IIGURI 3 - Mois ura Densi 7 for 3MP 278 - Nuciaar Censocato TICURS 4 - Mois:ura Cassi 7 for 3 M 278 - Sas! Cone Tests nGURE $ - Moisture Densi:7 for 3M 278 - Nuciaar Densi:7 ? ass 1=g Tas:s 71G:2Z S - Moistra Denstry for T2 2*3 - Sand Cena Passing Tests MG RZ 7 - 71sdev of Acceptab111:7 for Tas: Rasul:s MGURI S - U. S. Tascing Co. ?:ce:c: Method Cc=parisons nGU22 9 - Mois:ura Oensity for 3MP 273 - Adjus ad Moistura Con:an: -.
n GORZ 10 - Cc=parison of We: and Dry Reis:ive :ensi:7 C' .
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, 427IN CF C. S. T23TrfG TI2LD AND LA.30RATORT CONa M G doX ,
TEST DATA ON SOILS USED AS yILL 1
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l This review of de qualicy control :sses of de earth fin ac the Midland Si:a was made as a :ssul: of settlement of the fill supported diesel generacer building in exessa of chac predicted. Soil sastplas obtained in borings indicated that soil.condicious beneath da plant sc:vetures are not compatible vita de quality of fin that could be expected based on. de results of the control tests made by U. S. Tascing Company. ' All fin was ' accepted as 1: vas being placed based on the resul:s of the fiald tests pe: formed by U. S. Tasting Company.
i The review showed many discrepancias in the :ast resui:4 as cuc11 sed in de fonoving paragraphs. Review commancs are based on de requirenants of da cachnical. specifications for fin placemanc and :o subcontrac entered into by U. S. Testing Company.
- 1. Use of Laboratory' Test comoaction Cuz res Tabla 9-.1 of specification 7220-C-208, Page 143 required one field densin and noiscura con:an: :sse be :aken for each 300 cubic yards of fill placed.
I: also requirad'one compaction, grain size, and specific ' gravity for each 10,000 cubic yards of =acer141. ~his gives a ra:1o of 20 field densig
, tests to 1 laboratory compaction casc. Aldough 20:1 is not a stric upper i
W :, 1: is a guideline; should densi:7 :sses be cakan more. frequently l
dan one per 500 cubic yards.of fin the ratio could be hi;;har. The actual ratio is shown in Table A attached. In fact, some of the labora:on compactics :sses were used to detarmine percen c:mpac:fon for several hundrad field densin costs :akan over a period exceeding evo years. Ivan though no :ine cqui:enen:4 for -he period of use of labo:acory :ests are .
i specified, 1: is u. t miy that any borrow source in this area vould be of such uniforn charac:ar dae such e.xtended use of a conpac:fon cu:re. ::.d.y represancative of a la.ze quanti:7 of nacerial, would be applicabia. Listed below are selac:ad laboratory case data resul:s indica:ing tha vida range of soil proper.ias . hat varerspor:ed. Such a vide range is vpical for soils of .he kind used'in de fiu naking prediction of ~Wa densin, based on visual inspec:Lon ex:ranaly difficult if nee i. possible widou: tasting.
MIN. DENSITT N.A.I. DINSI'"! CPT. ICISTTRZ T2ST (1be/?c3) ' (1b s /'.3) (ce rnen t) l *5MP269 127.3 10
- 3MP273 11 7.0 13.2
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'5MP279 140.3 5.7
. ** RD2 4 100.9 119.2
- RD53 90.2- 109.7 . -
- R:61 109.3 123.3
$5MP = afars to proc:or ype tes:. - -
- RD refers :o rela:1va densi:7 :as: run by dry seded.
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Questionable Ratests A flaid density test that fails to =aet :aquirements of the spec 151-cation should have been reportad to 3echcal who chen would have required reworking of the area and :stasting.
Of the 668 "failing" :sses which were s:kad " cleared" by another :sst, in over 10% (72 tests) of -Je results, che clasting of cha "fallad" densi:7 test was apparently resolved by mara17 ushg anoda: lacorato:7 compaction cur re vid either lower saximum density, which resul:ad in
, in the percent compac ion bahs increased sufficiently, or diffe. enc optimum noisture conte.tt which caused the. fill to see: de requiranents of the specification. The possibility exists that soil was :s-oved af:ar a "failing" case and :aplaced by different =atarial, but the records do see hdicate this and it is not possible fren .he record to deta:nine if a new density :sst was nada. In other cases, costs labeled "fa11ed" were incorrec.17 cleared dough the same laboratory standard was referenced. For azample, in sona casas retasts co clear a " failed" cast were not taken in the sana area or at da approximate sana elevation. Mora than 40 recasts ve:a over 20 feet fron the " failed"
- sse location (as recorded in .he test reports) and some were over 200 feet from the orighal test location. h general, if af: : a "failu g" test the whole area is reworkad, da densi:7 :sst :.ocation is :oc :co cri:ical' ass
- g that de correct laboratory.cocpactice curve is used j . for comparison. However, in the plant fill work arass vera :alatively small, and soil cl. arac:aristics showed considerabia 'rariation necessi:a-l
( ting ratesting in de inmediata vicinity of the "fa111 g" cast. Katas t should be :aken in de lif: or soil layer dat has been reworked. Al-most 50 recasts vera takan at diff'arant eleva:1cus, scea up to 10 f:. >
from .he "fa11ad" :sst. I: should ba ocad cha: 3ech:a1 field personnel gave the loca:1cus for racas.1:g. This was soc a U. 3. Tasting rappon-sibill:7 Two : stases vers da:ad prior to the the the origi a1 :ss:
"fa11ad".. Over 120 "fa11hg" =asts vers :arkad as ("non Q") and sever I recorded cleared, as they vers ou:sida -Ja saf:ay rela:ad area.
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Table 3 is a compilation of nocas relac14e to questiceabla clearing of failed tests.
- 3. Theoracies11v I=cossible Test Rasui:s Soils cannot he note can 100 per ant satura:ad; :hornfore, all fiald I densi:7 test data poists, when plot:ad as d:7 da:sity versus :oistura conten:, =us: he belov he :are at: voids cu:re as defhed by :he specific s;avit7 of .he na:arial. Specifica.1cus do oc require exanhatica of da uro 11: voids curve, but 1: is considered cc:=ca prac:ica :314:1ve to c:npac:fon plots. Bars are cu= arcus casas in de 7. S. *asti:3 Compa 7 data whera points plot above :he :aro at voids cu re. 71gura 1 -
at: ached shows a typical labora:ory c:npac:Los :ss: curve vi:h field
- ss: :esul:s plo::ed on 1:. F.any of de field :ast resul:s are :o ,
datar:1:a pe::en: co=pactica ploc above che :ero 21: voids :u:re.
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?:ovided da specific gravi:7 is co;;ac: :his is ces possible so da:
- l. all such points mus: represas: er:eneous data.
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he fae: : hat a large number of tes: :ssui:s plo: above the caro air voids
.g4 eurve tends :o saka all :sse resul:s ques:1onabla.
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j Also, rafarring :o 71 3ure 1 1: vould appear cha: soil densi:7 varied 3
videly. Specifications called for cocepective effort . esui:s as defined by AS7M 01557 which is $6,233 f:-D/f=3 energy. n is was modified :o a f laborato:7 :sse compactive effor: of abou: 20,000 f:-Ds/f:3 energy, of:en 3 referred :o as 3echtal Modified Proc:or (3MP). I.aborato:7 compactica i
j :sse cu:-res should be rala:ed to the same effort as that called for in 5.
the field for use is comparing vic field densi:7 :ss:s :o determina 4 e percent compaction. Aacording to plots of fiald da a shown en Tigure 1, j densi:7 tha: tha varied from ab : 108 D/f:3 :o thout 130 lb/h3 h is doubtful jj ' soil classific ion or other properties vould be simila: for auch 3
a vide variation 6 danc :7 h 1.s co:ad :ha: 100 per:ent of modified i Proctor (AS7M D 1337) which is difficui: :o ob:ain, is raced a: 36,235 j f:-1b/f:3 energy. De curve plo::ad on Figure 1 is a: abou:. 20,000 f:-n/h 3 energy. ?ct comparative purposes 1: vas dete==1 sed be i tha 100 percant of specified effor. (20,000 f:-n/f 3)U. is S.approximacaly Testing in 1974 j
3, .h-D/f:3) Ref erenca Figura 8, equal to M per:ent of de "- dansW as decaded b
. 4 2= Racested use of Cues-ienable Laborstorr Tes Data '
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Sone labora:o:7 co=pa :1oc :ese da:a vara used :speatedly even : hough tha7
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3 con:1: cad :o shov suspect field :as: resui:s. nis could be indie'acive k
of questionabla 14borato:7 data or :he fac: : hat soil was . .cc behg placed sA or concern.co pacted accord 138 :o specifications. Ed: hor case ,is a cause for y,: V
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Several specift: gravi:7 calculaciens are 2 error, such as for 35 273 and 274.
j In the case of 3M 273, :he :erv air voiis curve passes :hrough the labora:ory compaction cu:re.
i In anothu exa=ple, 3MP 297, :he 14borator7 compac.1on curve is hvalid fua :o calculation er: ors, ye: vas :sfaranced j b7 fiald densi:7 :ss:s 22 cimes.
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Table C is a compilation of co:as rala:ive to quas:Locable :ss: da:4.
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Limits of Accuracr and Accestab111:v for Test Cata Figuras 1 through 7 at: ached vill be referenced in discussing limi:s of accurac7 of ac:ap ab111:7 for field :ss: :ssul:s as co= pared :o labora:o:7 i
- sst da:a. The figures show plo:s of compac:1on data for IMP 278 vhich are :7pical of all :ss: resul:s.
Specified labora:ory compac:1re effor: vas 20,000 f:-lbs/f:3 a:d field -
co=paction effo;; vas originally specified 4: 56,233 f:-ns/h' bu: vas changed by Revision 5, da:ed 7/3/73, specifica:1os 7220-Q-210, See:ica 13.7,, Page 37 :o also. be equal :o abou: 20,000 h-lbs/h*.
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- ne specified 20,000 f:-lbs/f 3 offert establishes a compaction cu: a relating moistura and deasiry for a specific soti. Moisture was specified for field placed, fill :n he vicin i 2 percent of optimum noisture as determined by this. effort. Density was specified to be grescer chan 95 )
perceae of .he maximum density. As compactive effort'is increased in the laboratory case -h densi:7 vin be increased and opci..um moisture content will decrease. 21s change can only cecur in de fiald to the extene that the field moisture concese viu pe mi: 1:. Once field a compaccion is such thac the fin dens 1:7 is significantly higher than 1 l
about-105 percent of ~%,the specified tolerance f:ca opc1=um noiscure concent in the laboratory compac:1on tasc.nay no longer be
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applicable for field control. A + 2 percent numerical value of moisture concent acceptable at d's specified compactive effort would be too vec at a higher effere since che sero at: voids curve defines the absolute naz1=um cha: can be achieved, indicating chac higher densi:1es for thac soil are impossible. nerefora, if the record shows high densities for such materf.al, the data are in error. nis was apparently overlookad. _
?.locs of field da:4 for compac:1on tesc 3HP 273 are shown on Figures 1
- hrough 6. . ne ci:la of each figure gives de assu=p cions made in ploccing data for' he. figure. In comparhg figures 3 and 4 h is seen ,
da: a majority of fiald costs were nade using :he sueleer device. "he evo case :esults shown on Figure 4 for the sand cone :: ached hdica:es one
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cast result on each side of the zero air voids curve. ne one faning f
above de-:ero-air voids curve (shovn on Figure 4) is designated by
\ U. S. Testing Company as the only passhg sand cone :est..(shown on Tigure 6). .
N' For a field :sse resui: :s be valid sa van as "?assing" h =us: fa n vi.h-in a van defined area on .he ploc containbg de laboratory ce=pae: ion curve. Bis area or whdow of acceptab111:7 is shews for a hypothetical compaccion curve on Figure 7a dat veuld nes: requiremen:s of Specificacien 7220-C-210. 3 is defhed by horizon:a1 Lines at 95 percen and lof percen:
of spec 14ded dans1:7, vertical lines drough 12 per: enc of opci=un meiscure :entene, and a 11ae paranel to de :ero voids line hdha:bs saturacion about half way between de compactica cu:ve and 100 perees:
sacuration (:are at: voids curve). ne practical upper l' ': et 10$
percent of speciliad densi:7 is nec defined in .he specifications. n was arbi::arily chosen as numbers greater dan :his give hereashgly invalid comparisons between field test resui:s and de specified laboratory compaction cast curve. Barefore,1.! an daca points fan *rithin :he defined vindev : hora vould be no reason :o assume dae : hey are v eng.
?.ovaver, when eny data poin:s fan outside de designated ares de:s is semeding.'.rong vid -he hfo:ma:1on and den an data pob:s becor.e suspec:.
A :eview of an data hdicaces da: abou: 25 perces: of :he cohesive soil tes: resul:s fan vthin .his area.
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Tigure 73 shows an area where field tes resul:s vould be acceptabla, in Geory even : hough not in se:1c: accordance vi:h .he specifica:icus.
?igure 73 was arrived a: by expanding Tigure 74 :o inchde :sse resul:s up :o a :cupactive effor: :ala:ed :o AS F. 7 1537 (56,253 h-lb/h*) which
- is considered :o be a prac:1:41 upper 11=1:. Ecouc 40 percen: of all cohesive soil :as: resul:s vould plot in this area. -
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. . . 1 Page 3 6.- Accuracy of Test Youlocene Almost all (over 933) fiald density testa on cohesive soils vers ade using the Nucisa: Consi:7 device. Specificacion 7220-C-210 section 12.4.2 page 42 indicacas this :o be acceptable for =oiscu:e con =ene dece==ination provided chat tha resules are compa 1ble vid chose obtained by ASTM D 2216. Sim112:17, seccion 12.4.4 says densi n deter-31 sed by. the nuclaar devica is acceptable vhan results are compacible
. vi.h densi:7 as determined by ASti D 1336.
b a. letter from U. S. Testing to 3echeal (dated May 30,1974), che average devia:1on of the nuclear devica from oven-d:7 =cisturas was
+.12% for a sa: of 30 cases. However, de standard error of ast1= ace is 1.8% for de da a vi:h the range of differaccas being from - 3.2% :o
, +3.9%. Thus, accuracy of de nuclear device is quescionable, and could
- anslace into ar ors of about i 4 pet in che dry danshy calculacion.
(It should be nocad chac errors 6 .he toiscurs concas :end :o shif:
the position of cast resul:s on a scistura dessin plot approx 1=a:aly parallel .co tha :ero air voids cu: re, assu=1sg .hs 6-place vec density is cc :ac:, and :hus do :ot explats da large su=ber of poin:s rhich plot ou:sida :he :ero at voids. Cc= para Tigures 1 and 9) .
No reliable co=ala:1on betveau sand :ena and suclaar densin :asts vara carried out :horsfora ders is no basis for decaWsing.14 U. S.
h.O Tasting would have perfor=ed be: tar using the sand cone procedure. .
However.1: is clear dat a large su=ber of the nuciaar densi:7 casts are v;ong. "his can be explained by considerhg de vec uni: weigh:
=ay have been .rrong or both de =ois:ura concas: and u=1: veigh: =ay have been v;ong. A reliable correlatica vid properly cenduc:ad sasd cone :asts should have :svealed dis, but 1: vas :o: appa:en:17 done.
- 7. Sala:ive Dansi--r Tests casas vara noted whers de:si:las in =aceriti classified on the fata sheet as :ces 3 (sand) vara ce= pared to .he azi=um densi:1as in proc:o type casts and ochar cases whera densi:1es is clay soils were co=parad :o che -=^m da sig is :a14:17e density :ss:s. An er:co; =ust exist 6 the record is such cassa aider -in the classifica:1on of the soil on
! data shee: or is co=parist fiald cast resui:s :o inapp;cpriata labora: cry 1 :ast daca. h 7,aneral, 1: appears da: :ela:17e densi:7 ases vera u. sed is cot::oillag dessi:7 of sand " " are vers a sig:14 han: cu=ber of ari-hse:ic er: ors on calcula:1on sheets aves dough dera are sii;:aturas on de sheets bdicatisg day had been checked. Ova: :.00 er: ors vers found 6 calculations, of rela:1ve dessi:7 fro: 3/15/79 :hrough 12/78 _
i (not all of dese er: ors change de accep abilig of de tes r es ul:s) .
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ASTM D 2049 see:1on 7.1.1 Vet Feched scates: "Noca 2 - Wile da dry mached is prefar:sd fran the s:andpois of securing resui:s is a shortar period of cine, de highesc *=*~= de=si:7 is obcalmed for some soils in -
, a saturated state. Ac che beginning of a laboratory test program, or when a radical change of materials occurs, the m'mm ' density rest should i
be performed on hoch vec and dry soil to decarmina which sadod rasul:s I in the higher nazimum densic7. -If the vst mached produces higher ym**m densitiae (in excess of one percent) it shall be followed in succeeding
- ss es . " An example of wee and dry relac1re dens 1:714 shevn on Figure 10.
U. S. Tasting Ocupany apprently did no: do .his frequently enough, or on, a broad enough range of son-cohesive soil :7 pes. As a consequence many ,
fiald densi:7 tesc :ssul:s exceed 100 percene of sax 1=um dry laboratory rela:1ve density. As an example, for laboratory :ss: 3.033 a tocal of -
$46 fiald : eses vere nada. Of :his total, 364 :sses were graa -- - %
100 percent compaction. The hishas: relacire decsi:7 found was 42.2
, perces: vi:h .he majority of casts over 100 pereant falling in a range of 100 percent to abouc 130 percan . Sinca he diffarance in =aximum densi:7 be:veen vec and dry methods is abouc 4 :o 3 lbs/c. f:. (based on 4
recene da:4) any :est resui: grea:a han abou: 115 per:ane (based on de
! dry mached) is suspect.
Even if 'the vec labora:ory :ast eded data vara availabla 5c: all sands, it appears an unacceptably high nu=her of field :ss: resul:s vould greatly ez:eed 105 percant relativa density avan based on the ve: ==v'~=.
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l s In summary, dare are five major faul:s con:alsed in :he Xidland compac:sd Fill Densi:7 Tast laports as follows:
- 1. er:eceous field densi:7 :as: da:4.
- 2. heorrac: scil idan:141 cation
- 3. inco n ec: (or quascionable) labors:ory :as: data.
4 calculation etrors
- 5. imprope: or bec=ple:s clearias of "fallsd" :sses.
I:ams 4 and 5 rep;ssene axis:1ss faul:s in :he data which could be corrected. However, as a resul: of ite=s 16:cush 3, there is no
- acicnal means of de:ar 'W vhiah :sse resul:s are valid and whi:h are noe. Shea mora dan one half of de :est :ssul:s for ra14:1ve density and par:an: c =paction fall outside the possible :heors:1 cal ::mparisec
, I N :s , 1: ,=ust be concluded dae :hess :ss: :ssul:s are suspace and shou.1d not be used alone for ac:aptance of planc area fill. Barefore, other means of :ss-d=3 have been established and a= ployed :o de: ::.ine if d a fill 6 any given area is acceptable. -
Also is 1:aa 4 1: should be nocad da: on =any :c:assions :ha i= place densi:7 was dividad' by :he =aximum densi.7 f::= de :ala-ive densi 7
- ss: :o sec perten: cespaction, thass :ss:s ve:e also used :s .isar c:her p:1c h s :ss:3.
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i ei 71BLZ A Listing of All Classifications ?,eferenced is ?lan: Area 7111 foil Test Records W'hich vere Used for 20 or More Field Dens 1:v Tests
, Classificatics* No. of Tests 3200 90 3231 31 3152 22 3234 42 3255 57 3260 68 3261 36 3262 165 3269 227 )
- 3270 226 3271 141 .
3274 37 3276 21 3277 15 8 i 3273 82
( 3297 R013 22 .
20 -
1016 61
\ R024 248 1030 54 R035 59 1038 39' R029 28 .
R040 35 R041 69 R042 103 1043 48 1044 71 1045 43 1049 63 1054 113 R055 566 1059 65 1061 589 R063 42
. 1065 39 Nota: Spec. 7220-C 208 gives a ra:1c of appro:ciza:ely 20 field
- ases :o each 1.abers:c: / =as:.
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I TABLZ 3 Zo,cas o on Questionable Clearint of ? ailed Tests
- 1. Test number MD 245 fails due :o high moistura. Cleared by MD 246 which :sferences a proc:or vi:h highar op:1 mum mais:ura con = ant (OMC) such =bac the 12% of optimum requiramanc is =st.
- 2. MD 205 fails with mais:ura contant 6: abova :he OMC. Claared by MD. 215, which rafarancas a :alativa dans1:7 lab standard, and is itself still 6* away from the CMC of the proctor rafaranced by MD 205.
- 3. m 223 fails because of high moistura. Cleared by MD 723 which has actually a highar acistura con = ant and lover densi:y, bia: rafarances '
a different proctor; the :stast passas and clears :he failure.
. - 4. 3eth MD. 844 and 886 fall because of high sciature and icw density.
They are cleared by MD 888 which refarancas a new proctor with levar maximum densi:y and higher Chc chan :ha ft:st.
- 5. MD. 251 fails due :o =ciscure bei:s too high. Cleared by C. 253 which uses a highar CMC proc:or.
l' 6. MD 668 clears E R 634, but tha :vo :ss:s show no cor:sspondseca is locacion, moistura, densi:y, or lab s:a=dard.
( 5 7. W 771 fa11ad, being too dry. Claared by MD 782, which has almos:
l- s idan:1 cal moistura contant and dry dansd .y bun uses a new 3MP with l ,
iceer optimum soistura.
l 8. MD. 2384 claars MD 2342, rafaracc1=g.a diffs:an: proc:c: vi:h as l CMC which' fi:s the in-si:u cond1:1ons. However, :he dry densi:y of 2. 2384 is vay too high :s fit the original soti classifica:1on, and in additica, 1: falls outside of :ha zero at: voids cu:ra for the classification which 1: has baan changed :o.
- 9. M $36 clears MD 554 by using a 3MP v1 h icvar =oistura requiraman:s.
The field densitias differ by 24 pcf and vet.1d see: :o be diffa:as: .
natarial.
, 10. MD".358 claams MD 115 but has too high a detstry to be the same soil as 2 555. 2: also uses 4 diffara== ;;cc:or.
+
- 11. 2 566 and 568, classified as EMP 262 cohasiva soils, are :laared by 2 . 569 vhich is classified as RD 33 a:d has totally differan:
- soil preparties chan :he :ve failurss.
~
- 11. MD 1317,16,19 and 20 fall a=d a:a all cleared by E 1477 :aken over 5 vaaks la:ar. hara is poor cor:aspondacca 1: :he soil prope::Las and :ha proc:or is diffaras: frem fa111:3 :s passi:3 :ss:.
- 13. 2 2965 clears 5 2963 vi:h a diffaras: p;oc:c: :hrough :he :as:
.Ot resul:s vould hava baan passi:3 vi:h :he origi al 3MP.
\
14 MD 1388, classified as IMP 273, is clea:ad by T.
1461, classi!1ad as RD 55.
)
6
. . . _ . .._ _ ._ . . . __ . .. s . . . . . . - . _
l
_. ,- , , _ . _ _ - _ . . . _ . _ . _ . . . . . _ . _ , _ _ _ _ _ . . _ ~ _ _ _ . _ _ _ _ _ _ . _ _ _ _ . _ . . _ . . _
1 l
l 6
V
- 13. MD .170, classified as RD 24 is cleared by M!T 173, classified as 1NP 234
- 16. MDR 287 fails with a relativa density of 77%. Claared by 2 R 291 which has .1 ped levar density but arhi::arily rounds up tha :slativa density to 80!; it passes and clears :he failure.
- 17. In all of. the following fiald densi:7 cases on sand, che passing cast h41 approximacaly the same or icvar densi:7 than r.he failures, but rafarancas a levar nax1=un densit7 3D lab s:andard:
MDR 343 clears MDR 339 MDR 314 clears MDR 507 MDR 513 clears MDR 508 MDR 515 clears MDR 509 MDR 516 clears MDR 510
. . MDR 522A clasrs MDR 521 -
MDR 558 clears MDR 556, 557 MDR 480 clears C R 473 MDR 555 clears MDR 523, 527, 534 4
MDR 533 clears MDR 526, 530, 531
f '
- 21. MDr.1694 cisars MD. 1693 but is 43' away fron :he si:a of the ft:sc
- sse.
- 22. E 3114 c1:.ars MD 3102, but :ha :.ro :ases are 68' apart.
l Nota: W3 entia gives tyyttal obsa: rations and is nec meanc :o be al*-
inclusiva.
l N gae s
- g. .
e
.,,.w, .-,.,vm..,one-, ,,--,,3 w w ,, -.*--,w.,-,% w.---v-w.v...w,+ww--ee ee ----va-mM*--eee"*--*~we-*'+e-**v~*
~
,. . 1 p) .
i (V ,
l
( TABT.I C l t -
Notes on Ouestionable Test Data i
- 1. ne fi sc field densi:7 =ast to referenca 3D 24 (5/75) has a relative density of 170.6%. na standard continued to be used, however, vi:h relative densi:1es grascar than 100% occuring repeatedly.
- 2. Similarly for 2D 30, the first two casts (9/75) have 1142 and 122 relative densities, yet the standard vas. used for 10 months, 54 ,
tests, vich 52% of ths results over 100%.
- 3. During the ft:st two weaks of use (7/76), RD 41 was referenced 22 timas wit;h 12 casts over 100% relativa densi:7 (5 casts ove: 110% ,
i sad 3 over 1200. n e standard was used for 5 months, however, vi.h over 40% of the resul:s over 1002.
- 4. na first cast us1=g 3D 55 (8/76) has a relative densi:7 of 119%,
vi.h :ha field test bei:3 nada the same day as the standard and,
. thus, assumedly the ssna sacarial. nasa resul:s veuld :hrow doubt on tha lab standard, ye 1: vas used for :vo full years and 566 :ssts, vi:h 64% of the resui:s over 100: rela:1ve densi:7 p 5. Even high density structural backfill standards such as 3D 61
, (maximus 'dansi:7 of 115.3 pef), used 593 :ines, show over 252 of the tests having 3: sata :han 100 alatt,ve density.
k 6.
De ft st seven tas:s referenc1:g 3MP 269 (scat:ared over a em =en:h Period around 7/76) all fall outsida :he :are at voids curve. ~his classification was used for 11/2 yat:s, rafaranced 227 :ir.es.
- 7. Sa ft:st vo :sses .:stareccing 3M 270 (7/76) f all 6 pcf above :he zero at voids curve. Continued use of :his proctor for over 1 years resultad in 226 tests vi.h 82 outside tha :hacratical max 1=un.
- 8. For .he ft:st- mon:h (4/77) all 3E 278 :sste fall on or ou: side :ha ,
zaro air voids curve. To: the next non:h, over half the :ss:s did the same, or have graats: chan 1052 co=paction. D e sta=dard was used over half a year, vi:h 43 out of a :ctal of 32 casts outside the :are air voids cu:ve.
Nota: nis :abla gives typical observaticus and is :ot nean: en be all-inclusive.
(
ll 0
\
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. _ - . . . .,.,. - . _ ..._ _ _ . _ _ _ . ~ .._._ ....._.. ... _ -_.._.. _ . _ _ ____ _ ._ .. _.___ _._. _ .
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1
-M E1I S T LlR E -SPECIFIC TI E N15RRVIT S I T YY = F 2.ElR 6'.I fb M P 278 ~
~ . i FILL TESTS '
ci ,
ci . .
O ^
sp i
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S Zero air volde curve for tleis material 1
d -
I
- 1 Zero air volde curve for S.C. - 2.75, shows: for refetcace.
, 87 ,
IL
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.lill 't.lill U.011 12.110 16.00 2 0.110 2't.D U 20.011 3d.Dil
~
MBISfilRE CONTENT 13ti3 '
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4
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MSIETLlRE 'S DENB1 FY P E C If~ I C GRRVITY = 2.6 E '.
E2 M P 27o. '
1 1 SRN31-Cl3NE PRSSING TESTS * ~
,- c. -
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1
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a c. .
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I
- I
_ __________ . . _ ~ _ _ _ .
4
- =
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- g. 105 % ...... e# 1 9g CATA POINTS THAT PLCT IN SHACED AREA
, l 7,9 WOULO SE GENERALiY ACCEPTABLE G '
d- ACCORQlNG TO SPECIF_l. CATIONS
'4
===----
h 100% NCTI: A8 j- PLOTS IN THE 25% ALL FIELQ CATA AREA w
g ,, _____I 6
E I I I g l- I g i !
! I s -
e, l '
t-l l s g s W I I 2 CPT +2 MCISTURE CONTENT. PERCENT FIGURE 7 A.
i ,/ s DATA PCINTS THAT PLOT IN SHADEC AREA
\ 100 % -w---- -
\ ,
WCULD BE ACCEPTA8LE REGARQLISS CF a
ASTM 'e9- EXACT SPECIFICATION WORDING h 1557 ff o
.$ '$ NOTE: A80VT 40% CF ALL FIELD CATA
$ POINT 3 PLOT IN THE SMADED AR EA o e b
5 ixx ___. .
d SMP \e-b 1>
95 % -~~--
{ 'O,,o, I
i l \
' \
l l SMP l N I i i s l l %
l I i \
, ,. f, 2 CPT +2 WCISTURE CONTENT . PERCENT FIGUR E 7-8
\_
FIGURE 7: WINDOWS OF.ACCE?TASILITY (A) SASED CN SMP SPEC!FICATICN (S) AEGAROLESS OF EXACT WCRCING CF SPEC!FICATION l
. _.--. .. _ . - - . - - . _ _ . _ _ - - - . - ~ ~ - -- - - . - - - - - - ~ ~-- -- --- -- - - -- - - -
.. , . . .c.;:. w- ' * . - ~ ~~-
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,. a UNI'CD STATT.S T?S'CING CO. , DIC.
, .g - Graph Represer.cacion of Three
/Zo 1. , ' Proccor Mached Cc ycisons '
g June 1.3, 2.974 i
w
. 3:7 ?acar Weg A
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l M S IS T LlR E - 3] E N E _ T Y FBR Ila M P 27.. -
- ; SIE C I F I C. G R R V I T Y = 2.6's .
FILL TESTS' N -
3.5I Subtracted from Hofstiere Coutcut, Dry Density Recalculated
] ri- *
,_ 'S NOTE; Not only does a 3.51 i shift in moisture content
" ' fall to bring tests fuside *
- {*
r; the zero-adr-voids-curve.
{ E it results In $mipossibly n
laigla dry densities. -
- i li.
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. R_ o t . t_4 82 3 o l
- l > !" X X %
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- . 0 11 * .11 0 0.00 12.00 l$.00 20.00 2*i.00 20.00 32.00 j PIB I S T U RIE CONTENT 0%) -
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122
> > -- / -
EG O e
v h
b 117 i.
E 3
c- .
w U WET
- hi METHOD' 3 ..
O RY METHOD Q .
'O 100 116 RELATIVE DENSITY , (%) ,
NOTE: VALUES FOR ORY DENSITY ARE TYPICAL OF A RANOOM FILL SAND.
' ANY TESTS SHOWING MORE THAN 117% RELATIVE DENSITY WOULO BE SUSPECT IN THIS EXAMPLE. STRUCTURAL SANDS TEND TO SHCY/
ONLY 2 OR 3 PCF INCREASE IN MAXIMUM OENSITY ANd THUS RESULTS AT MUCH LOWER RELATIVE DENSITY WOULO SE SUSPECT, SAY 105 - 110
- ERCENT O. FtGUR E 10 -
CHANGE IN RELATIVE DENSITY SCALE FROM ORY TO WET METHOCS
' OF OBTAINING MAXIMUM OENSITf , 3ASED ON RECENT LAB RESULU
_ _ - _ _ m . _ . __ _
i
( (
' ATTACHMENT 12 1
.. ,1
- I\.
' Docket No.
)p \
Docket No. 5'd':T30 Consumers Power Company
(; ATIN: Mr. Stephen H. Howell Vice President 1945 West Parnall Road *
' Jackson, MI 49201 l
Gentlemen:
This. refers to the inspection conducted by Mr. E, J. Gallagher of this _
. office on September 11-14, 1979, of activities at the Midland Nuclear i- Power Plant construction site authorized by.NRC Construction Permits No. CPPR-81 and No. CPPR-32 and to the discussion of our findings with Mr. B. J. Marguglio and others of your staf f, and others of the Midland site staff at the conclusion of the inspection.
f The enclosed copy of our inspection report identifies areas examined t; ( during the inspection. Within these areas, the inspection consisted of. ;
a selective examination of procedures and representative records, obser-vations, and interviews with personnel.
During this: inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed
. Appendix A.
This' notice is sent to you pursuant to the provisions of Section 2.201 of l the NRC's " Rules of Practice," Part 2, Title 10, Code of federal Regulations.
l Section 2.201 requires you to submit to this office within thirt'/ days of
~
L your receipt of this notice a written statement or explanation in reply, L including for each item of noncompliance: (1) corrective action taken and .
the results achieved; (2) corrective action to be taken to avoid farther noncompliance; and (3) the date when full compliance will be achieved.
Based on our telephone discussion with you on September 21, 1979, it is our a understanding'that the personnel performing inspections of the prestressing l- system wnose qualifications we consider do not meet the provisions of Regu-L latory Guide 1.53 and ANSI N45.2.6 have been relieved fecm such duties until I
further evaluation of the requirements and further discussion with the Regton III office. Please include in your response your plans to recenfirm >
the qualifications of other personnel performing quality control inspections ,
on the Midland project. t n
u.
.79/t a co7A
l
(
- i
/
/% 4 l
j 2
t v W
. ~. 3, V. Consumers Power Company In accordance with Section 2.790 of the NRC's " Rules of-Practice," Part 2, <
Title 10,-Code of Federal Regulations, a copy of this letter, the enclosures, and your response to.this letter will be placed in the NRC's Public Document Room, except as follows. If the enclosures contain information that you or your contract, ors believe to be proprietary, you must apply in writing to this office, within twenty days'of your. receipt of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietar/,
and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, Gaston Fiorelli, Chief Reactor Construction and Engineering Support Branch
[
Enclosures:
k 1. Appendix A, Notice of Violation IE Inspection Reports 2.
No. 50-329/79-19 and No. 50-330/79-19 cc w/encls:
Central Files Reproduction Unit NRC 20b
NSIC TIC Ronald Callen, Michigan Public Service Commission Dr. Wayne E. North
( 'iyron M. Cheerf, Chicago O)
\.
Rmp.9 un "g g Rm.
Rm
-c am n
l Gallagcer/bk Hayes FiorIlli Cook ~(*~
Vandel h 9/2t/79
_ _._ , _,, . . ._ . . _ . . . ~ . . . , _ . . . . _ . _ .
i
'I-l l
Q. l (J'
\
Accendix A 1
NOTICE OF '!I0I.ATION Consumers Power Company Docket'No.30-329 Docket No. 50-330 Based on the results of an NRC inspection conducted on September 11-14, 1979,' it appears that certain of your activities were not conducted in full compliance with NRC requirements as noted below. These items are infractions.
- 1. 10 CFR 50, Appendix B, Criterion III requires, in part, that appro-priate quality standards are specified and included in design docu-ments and that deviations from such standards are controlled.
CPC0 Quality Assurance Program Policy No. 3 states, in part, that "the assigned lead design group or organization assures that the design and material are suitable and that they comply with design crite ria and regulatory requirements."
Contrary to the above, Specification C-211, sections 3.1.2 and 8.2.4 l
! n$. permits the use of lean' concrete as a-substitute of safety-related
' (d structural backfill and: compacted sand material while stating that
" lean concrete shall be made.of non-Q material and workmanship".
l- This permits.the use and. installation of non-Q (non-safety related)
-material in safety-related areas without benefit of the licensee's quality assurance program. Non-Q (non-quality) lean' concrete has been used in various areas of the plant fin including observed areas in the safety-related tank farm area.
- 2. 10 CTR 50, Appendix' B, Criterion II requires, in part, that the l quality assurance program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
CPCO Quality Assurance Program Polic'f No. 2 complies with the require-ments of Regulatory Guide 1.58 and ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants" In addition, the licensee's contractor, Bechtel Power Corporation, procedure G-8.1 section 5.2, requires l specific education and experience requirements to be satisfied to be considered for certification as a Level I inspector. Those requirements
'nclude: Two years related experience or high school graduate plus one year related experience or college level work leading to associates l
degree in related discipline plus six months of related experience l
i l s%
l \
l l
%v) b6 of t L 1%IN0070
-n. . . , - -...- - - . . . . _ . . . . . .. - - .- - - . . . . _ . , . .
h
(. k 2 . <' :
\
g Appandix A ,
, 1 in equivalent-testing, examination or. inspection activities associated with power plants, heavy industrial facilities or other similar f a cihties . -
r Contrary to the above, five QC inspection personnel performing measurings,. tests and examination of the containment prestressing system were'not qualified in accordance with the above prerequisites
. in that they had no prior related education nor prior related work experience.in equivalent testing or inspection activities.
' t 4
a 9
. I I
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i
.-....E..m-v.m.,. ....,-a.--~e-.- --m.....m.-.m.%,.w,wm--~..-..__ -,.%--..--,,-,.mv-v,... _ . - - . . _
.,*,m..,,r.L,,-<
/
(} ,
J -U.S. NUCLEAR REGULATORY C0f01ISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-329/79-19; 50-330/79-19 .
Docket No. 50-329;!50-330 License No. CPPR-81; CPPR-82 Licensee: Comsumer Power Company
-1945 West Parnall-Road Jackson, MI' 49201' ;
Facility Name: Midland Nuclear Power Plant, Units 1 and 2 '!
Inspection At: -Midland Sice, Midland, Michigan Inspection' Conducted: September 11-14, 1979 U Inspector:
kC E.J._Gallagher Q 5)*N
<7 - /73 3
/e f,ds~['1
, Ismo Approved By: D. 7 Hayes,#Chhef Engineering Support Section T' Inspection'Summarv E Inspection on September 11-14,1979 (Repo rt No. 50-329/79-10: 50-330/79-19)
- -Areas inspected
- Containment prestressing system work procedures, work activities and quality records (units l'and 2); QC inspector qualifications; status of soils wo~k activities'and 50.55(e)' reports relative to contain-ment prestressing system'and concrete expansion anchors. The inspection ,
involved a total of 27 inspector-hours by one NRC inspector.
! Re s:,;g: Three areas were inspected. Two items of noncompliance were identified in the areas inspected. (Infraction - inadequate design control -
. Paragraph 2.a; Infraction - inadequate QC personnel qualifications - Para-i graph 1.c).
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' DETAILS
'gerjons e Contacted Principal Licensee Employee's (CPCO)
- B. W. Marguglio, Director Quality Assurance
- D. M. Miller, Site Manager
- T. C. Cooke, Project Superintendent'
- 0. T. Black, Quality Assurance Engineer
- R. Wheeler, Staff Engineer
- *J. L. Corley, Section Head - IE & TV
- D. Horn, Civil QA Supervisor Bechtel Power Company
- J. A. Rutgers, Project Manager
- W. L. Barclay, Project Quality Control Engineer
- A. J. Boos, Project, Field Engineer
- W. J. Creel, Quality Assurance Engineer
- L. A. Breisback, Project Quality Assurance Engineer
- Denotes those in attendance at exit meeting, r
( Licensee Action on Previously Identified Items (Closed) Noncompliance (329/79-10-01; 330/79-10-01): Inadequate control of design interfaces; (a) Specification C-2 specified material for pre-stressing system sheathing to conform to ASTM A-366-66 or 68 while FSAR
- Section 3.8.1.6.3 required ASTM A-513, type 1, Grade 1010-1020 or A-53 type E or S, Grade B. FSAR Section 3.8.1.6.3 has been revised via amend-ment 22 to be compatible with specification C-2 requirements. (b) Speci-fication C-49, Section 6.2.2 specified the chemical limitations for prestressing system corrosion protective grease to be a maximum of 5 ppm chlorides, nitrates and sulphides while FSAR table 3.3-25 required 2 ppm (chi sride), 4 ppm .(nitrates'; and 2 ppm (sulphide). Specification C-49 has been revised via change notice 9004 to meet the commitments in the FSAR.
(0 pen) Unresolved (329/79-10-02; 330/79-10-02): Unavailable quality records rela *.ive to performance tests on prestressing system; items 1 and 2 of the unresolved items remains unresolved since the quality records are being researched. Item 3 relative to buttochead rupture tests quality records were made available and reviewed for tendon V-79, V-77, V-32, V-33 and found acceptable. 1tems 1 and 2 will be pursued during subsequent inspections.
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. 1 V' Functional or Program Areas Insoected During this inspection the containment prestressing system procedures, work activities, quality records, and inspection and testing personnel qualifications were inspected. In addition, significant construction deficiencies reportable in-accordance with 10 CFR 50.55(e) relative to containment prestresstnc system, concrete expansion anchors for component supports and site soils end settlement were reviewed.
- 1. Containment Prestressing System (Unit 2)
- a. Procedures j The inspector reviewed the following procedures for containment {
prestressing work activities: L (1) C-2, Revision 12 (> fay 10, 1979) including FCR C-1986 (revised stressing sequence), FCR C-2046 (calibration of stressing jacks and gauge). INRYC0 had approved the [
changes.
(2) C-2-146-9,~ Field Installation ?!anual, including FCR Nos.
2062, 2049, 2048, 2047, 2041,'2042, and 2020. ,
(3) PQCI-9.10, Inspection of Post-Tensioning System l
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\ C-49, Revision 2, Tendon Sheathing Filler ?!aterial and FCR (4) 2069 SCN 9003, and SCN 9004.
l The inspector indicated to the licensee at the exit meeting that PQCI-9.10 had not been revised to the revised requirements of C-2-146-9. The licensee informed the inspector that the changes would be incorporated and that the QC inspectors are aware of the field changes in effect.
- b. Reportable 10 CFR 50.55(e) on Prestressing Tendons Notification in accordance with 10 CFR 50.55(e) was made by licensee on July 26, 1979 that a nunber of containment pre-l stressing tendons were fabricated and shipped to the site with indeterminant wire lengths and in violation of the 1/8 inch maximum wire differential. MCAR 33 was issued on July 27, 1979 documenting the deficiency. NCR 2373 was also issued placing
, the 7 verti:a1 tendons already installed ta the Unit 2 contain-l ment and 10 hori:entals receited in storage at the site on
! hold.
Inspections by the licensee at INRYCO's Melease Park, Illinois facility and Niremill facility in Ficrida were performed to ,
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3j investigate the cause and which facility is responsible for the fabrication of the deficient tendons. It was determined that the tendons fabricated at the Wiremill facility produced the tendon with differentiated wire due to the following reasons:
(1) back tension device was switched off and not operating resulting in varying wire lengths, (2) catcher clamp was found to be damaged due to weld fatigue, and (3) limit switch had excessive travel. These three mechanical deficiencies contrib-uted to the production of differential wires in the tendons fabricated.
A total of 38 tendons have been fabricated at the newly opened Wiremill facility. Tendons traced were as follows:
Seven vericals installed (on-hold)
Ten horizontals on-site in storage (rejected and shipped back to INRYCO)
Seven verticals (on-hold at Wiremill) .
Ten horizontals (on-hold at Wiremill)
INRYC0 has submitted a salvage procedure for the seven verticals i installed in Unit 2. Procedure F-365-9.2 Revision 1, was-
[ currently under review and comment which proposes a method to Q field cut. and modify to satisfy requirements.
Bechtel has performed two quality program verification surveys of the B7YC0 facilities. Results are documented in QPt*S No. 9Q and 10Q. In addition, a Bechtel inspector is stationed at the Wiremill facility to perform continued inspection of the tendon fabrication.
The b7C regional office will review the final 50.55(e) report upon receipt.
.c. Qualifications of QC Inspectors f'or Prestressing Work Activity During a May 14-17, 1979 inspection (report No. 329/79-10;
( 330/79-10; page 4) the NRC inspector had indicated to the licensee that none of the 3echtel QC inspectors to be assigned the inspection and testing of the containment prestressing system has any prior related work experience on prestressing syste ss nor construction of power f acilities. At this time no work had begun on the installation of the prestressing system.
The inspector, indicated that this natter '-ould be reviewed l during folicwup inspections.
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1 During this inspection the matter of qualification of quality control inspection and testing personnel was once again reviewed.
The personnel qualification and training records of eleven quality control personnel were reviewed and compared to the requirements of Regulatory Guide.l.58 and ANSI N45.2.6. It was concluded.that five of the individuals certified as level I inspectors'were not qualified in accordance with the above standards as well as Bechtel program requirements contefied in PSP-G-8.1, Qualification, Fvaluation, Examination, Training and Certification of Construction Quality Control Personnel.
Section 5.2 (Education and Experience Re'quirements) of G-8.1 requires that one of the following requirements be satisfied in order for an individual to be considered for certification as a level I inspector:
(1) 'Two years related experience in equivalent testing, exami-nation or inspection activities associated with power plants, heavy industrial facilities or other similar facilities.
(2) High school graduate and one year of related experience in equivalent testing, examination or inspection activities
- associated with power plants. . .
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, _ -(*) (3) Completion of college level work leading to an Associate !
Degree in a related discipline plus six months of related experience in equivalent testing,. examination or inspection activities associated with power plants. . .
It is important to note that the above requirements are also included in Regulatory Guide 1.58 and ANSI N45.2.6 and requires education in a related disciplice (i.e. technical, engineering, etc.) and prior work experience in a related field of testing, l- examination or inspection activities (i.e. concrete, soils,
! prestressing, etc.) ,
l l The personnel qualifications of five of the QC inspectors l certified as level I indicated no prior related education nor l pre,e related work experience nor prior related construction exp rience. A summary of the individuals qualifications are contained in Appendix I. These individuals have performed various QC inspections on the Unit 2 containment prestressic;
,- system. It is important to note . hat the remaining six QC
- inspectors have not had any prior experience with prestressing systems, however, they have had prior construction experience.
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(v) Discussions with the licensee's contractor Project Quality Control Engineer (PQCE) indicated that an attempt was made to secure fully qualified personnel through the corporate office.
However, that office was unable to supply'the requested per-sonnel based on comments by the PQCE.
The licensee's contractor (3echtel) informed the NRC inspector that Section 5.1.2 of program G-8.1 states, "The education and experience requirements specified below shall not be treated as absolute. These requirements may be altered when'other factors provided reasonable assurances to the supervisor responsible for certifying a lower level candidate that the person can competently perform a particular task." J The license indicated rela: cation of the education and e:cperience requirements was exercised based on the above provisions.
The inspector informed the licensee that while it was fully recognized that the requirements for education and experience are not absolute,.the intent of the Regulatory Guide 1.58 and ANSI N45.2.6 was that the individual has prior related education and related experience while perhaps not the exact length of time.
The inspector indicated to the licensee that the liberal inter- 3 m pretation of the requirements were unacceptable and considered
( to be an item of noncompliance with 10 CFR 50, Appendix B,
\v} Criterion II. (329/79-19-01; 330/79-19-01)
- d. Observation of Prestressing System Work Activities (Unit 2)
The inspector observed selected work activities relative to the Unit 2 prestressing system. The following specific items were observed:
(1) Tendon D124 stressing using calibrated Jack No. I and Gauge No. 191; Bushing ID MW-303, Beaning Plate GM-257; lock off load and tendon elongation were within predicated range.
,. (2) i Gregse 140 to tank,F.
210 temperature 152 F; required temperature is (3) Tendon D412 stressing; Field Anchor ID MQ-120; Bearing Plate GS-136.
(0) Completed Tendon D-124 and D-312 The s' ave work was obsc.ved to be perfc emed according to the prescribed work procedures.
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- e. Quality Records for Prestressing System (Unit 2)
The following prestressing system qyality records were reviewed:
(1) Nonconformance Reports NCR-2205 (0 pen) Lack of acceptance / rejection criteria for rust and bent wires on tendons H13-252 and H13-24 ;
NCR-2505 (open) Tendon D-301-2 had 5 wires broken during -
stressing.
NCR-2372 (0 pen) Issued 50.55(e) on differential wire lengths.
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NCR-2382 (Closed) One wire on shop-end buttonheaded but sent to site - wire repaired.
NCR-2383 (0 pen) Tendon H21-234 and H21-236 inspected with "E" rust status - unacceptable rust - wires pulled for testing.
The above NCR's will be reviewed when fully dispositioned by the licensee.
O (2) Buttonhead Repair Log This log tracks the buttocheads inspected and indicates the number defective and repaired in order to meet speci-fication requirements on permissible number of buttocheads defective. Tendon V-90 indicated six buttonheads were defective after repairs =made. Specification C-2 permits only four. The licensee indicated V-90 is being reviewed and repairs to be recommended by engineering.
L (3) Stressing Gauge Dial comparison l .
l The stressing gauges are compared to a master gauge once
- daily. If the gauge is determined to be out of calibration t
the last tendon stressed is completely restressed with a
( calibrated gauge. The new stressing valves are then l
compared to the work performed with the uncalibrated i gauges and evaluated to determine if other tendons require wo r r. ,
i Tendon D-321, V-23 and D-121 were restressed due to gauges
- betag out-of-calibration.
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~ (4) Field Muttenhead Records - Tendons V2-2, V3-2, V13-2,
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V14-2 and V54-2 were reviewed and found acceptable.
The inspector indicated to the licensee that the quality for the tendons completed to date have not been completely I assembled in- order to perform a complete review of each tendon. Various inspection and quality documentation is j located ;in various files without a complete review of an ,
1 individual package as required by the Field Inspection !
report.
- The, licensee indicated the completed tendon package would "
be assembled and reviewed prior to final acceptance of the work. !
- 2. Review'of Site Soils and Settlement ;
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- a. Backfilling Procedure .!
i Specification C-211(Q), Revision 7, Structural Backfill, Section i' 8.1.2 and 8.2.4 permits the use of lean concrete in lieu of structural backfill and sand backfill material. This specifi- !
cation is used~for placement of safety-related soils. The ,
above sections state, " Lean concrete shall be made of non-Q s (non-safety related) material and workmanship." i j
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\, The inspector observed lean concrete material placed adjacent 1 to the borated water storage tanks in the tank farm area which j is designated as a safety-related "Q" area. The licensee l
' informed the inspector that previously placed lean concrete d material in safety-related areas were also designated and placed as non-safety related material.
i 1 10 CFR 50, Appendix B,, Criteria III requires that appropriate l quality standards are specified and that deviations from such .
!, standards are controlled. Contrary to the above, materials I l being used in safety-related struptures were specified and L
permitted to be of non-safetf irelated material and workmanship.
The quality assurance program has not provided control cver this safety-related work activity.
1 This is considered an ice.m of none:mpliance with 10 CFR 50, Appendix 3, Criterton III (329/79-19-02; 330/70-19-02)
- b. placement of Soils f f
Specification C-211, Section 3.5.1 requires that equipment ;
j' being used to compact soils be qualified prior to use. Quality i l control initiated NCR 2492 on August 30, 1979 due to Bechtel ll [
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Av J-construction use' of an unqualified type of handheld compaction equipment ("po-go stick") in safety-related "Q" areas. The Bechtel project field engineer dispositioned the NCR as not being. valid while being aware of the specification requirement.
The "po go stick' was again later used in safety-related treas.
- t. Bechtel QA department subsequently issued Stop work report No.
6 for use of such equipment until such time that the nonconfor-mance was resolved.
The licensee'has-indicated'that Bechtel.Geotech has directed the . field to qualify the equipment as required prior to any further use.
The NRC inspector questioned the licensee why the project field engineer was permftted to disposition the NCR as invalid and again permit the use of the equipment'in violation of the requirements. The licensee indicated that the quality management personnel.would take appropriate action to preclude auch events- 1 and that QA acted promptly in issuing the stop work report.
- c. Status of Site Settlement The surcharge load in and around the diesel generator building has been removed as of the end of August, 1979. Soil response
, to the removal of the surcharge is being monitored. Discussion
't . . with the licensee, Bechtel Geotech and DR. Dunnicliff indicated j' that the soil has rebound approximately 3/16 of an inch; expected l rebound is predicted to be on the order of 1/2 inch or less.
l Temporary dewatering system in the vicinity of the Unit 1 and 2 valve pits have been installed, however no pumping or drawdown of the. ground water had begun at the time of this inspection. 1 Pile tests are being planned'in the vicinity of the service water pumphouse structure. Tests are to begin in early October by Bechtel Consultants. .
- Excavation of sof t-material in the borated water storage tank
! farm was in progress with placement of sand material inside and around the tank' foundations. Sand was being placed using qualified handheld compaction equipment to S5% relative density
- for support of structures and 30% relar.ive density for areas
! other than under. structures.
l 3. Review of 50.55(e) on Concrete Exoansion Anchors Specification C-305, Revision 9, Section 6.2.2 requires sheli type expansion anchors to be tension tested :: the specified loads. In l
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-addition, in-process inspection is required. Because in-process . 1 inspection had not always been performed it was requested to randomly select _60. anchors to verify adequacy of past installations.
. Af ter testing 32 of the anchors, the 'results indicated nine failures where the anchor slipped prior to achieving the test load. At'this time :-! CAR 34 was ' issued on August 21, 2979. Results are documented on NCR-2461 and NCR-2431.
Engineering re quested another 100 anchors to be inspected -( T',G-5383
. dated August 2L, 1979) for proper setting and tension tests. The results of the' additional tests are documented on QCFl!-6560/AI-667 dated September 6, 1979. . Visual results indicate 20 acceptable and 82 unacceptable (i.e. not fully set). Twent'/-three (23) could be reset. Sixty (60) 3/S inch anchors were tension tested of which two failed while-37 1/2 inch and five 5/8 inch were tensioned and found acceptable.
The' licensee indicated that approximately 900 cf the shell type anchors have been installed prior to identifying the deficiency.
Because of the above information the licensee reported the defi-ciency in accordance with the requirements of 10 CFR 50.55(e).
The licensee is continuing to evaluate the results of the testing and what corrective action is required to resolve the deficiency.
f The final 50.55(e) report will be reviewed upon receipt by the NRC.
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Exit' Interview The inspector. met with the licensee representatives (denoted under Persons Contacted) on September 14~, 1979. The inspector summarized the scope and findings of the. inspection. The findings were also discussed via telephone with ?!r. 3. !!arguglio and management of RIII NRC on September 17, 1979.
The licensee acknowledged the findings as reported.
Attachment:
Appendix I
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u _ v APPENDIX 1 PRESTRESSING SYSTEM ()C PEltSONilEl. 4)tlAI.IFICATIONS On-Site Ara;as of 11cch t el Certifled Related Related Experience Training Inspection l ud i v i d u.il Fniploye e I.evel 1 Education none-janitor,- 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> - Tendon insertion, A 7-12-79 8-6-79 none-cook, ICA buttonheading, high school stressing, greasing (1st shift)
_ _ - - O 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />. Tendon insertion, is 1-12-79 8-6-79 ione- none-h 'th school Haniada Inn, burgonheading, printer stressing, greasing (1st shift) 7-12-79 8-6-79 none- none- 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> ' Tendon insertion, c buttonheading, 3 year student college last stressing, greasing (2nd shift) none- 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> Tendon insertion, p /-16-79 8-6-79 uone-M. A. student buttonheading, Musiness last stressing, greasing (1st shift) q none- 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />. Terminated on 8-10-79 E /-12-79 8-6-79 none-high school bar tender i
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- b) v ATTACHMENT 13 f'* t,%
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~ (j -[ % % i j UNITED STATES NUCLEAR REGULATORY COMMISSION
/g / WASHINGTON, O. C. 20$55
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Occket Nos. 50-329 '
and 50-330 APPLICANT: Censurers Power Ccmpany FACILITY: Midland Plant, Units 1 & 2
SUBJECT:
SuttARY OF JULY 18, 1979 E ETING ON SOIL DEFICIENCIES AT THE MIOLAND PLANT SITE L
On July IS,1979, the NRC staff met in Sechesda, Maryland witn Consumers Pcwer Ccmpany and the Sechtel Corporation to discuss deficiencies in the fill used at the site for Midland Plan:, Units 13 2. Also presen: were representatives of the ACRS staff. Meeting attendees are listed in Enclosure 1. 4 in response to NRC requests, the applican has documented in detail :ne presenta: ions given during this meeting. The presentations are contained
,,, in S. H. Mcwell's letter to J. G. Keppler dated August 10, 1979. In i
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view of the August 10, 1979 letter, no sumary of the presenta:f ons is centained herein. Rather, additional discussion consisting of cemen:s and questions given dur4ng and follcwing the presentations are sumari:ed.
During the presentation regarding remedial work in progress or planned (item 3 of the presentations), the staff noted that underground piping from :he berated water storage tanks and service water lines ; ass uncer railroad tracks, and that these and other piping are subject to loads due to construction cranes and other traffic. The staff requested the applicant to descrice the design features anc ether measures wnich assure .
that such piping is not subjected to excessive loads. The applican will respond at a later date.
The applicant noted that it is performing lacorat:ry inves:igations of the stainless steel piping removed fecm the concensa:e s:crage tank.
This undergrcund piping was fcund to be heavily corroced. I eras noted that the injection piping frem SWST is of the same composition and is also unprotec:cd from electro-chemical attack. The tas:-cits in :he
, tank farm area which are ceing dug to investigate ne effect of :he air. discharged frem uncerground ;neumatic lines was also cescribec.
Results will be reported snortly.
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(s -Consumers Pcwer Ccmpany ,.
5b The staff notec : hat the responsa :o its 10 CFR 50.5a requests for ac:eo:ance criteria for remecial actions (e.g., ques:fons 4,'5, etc.) hac not resul:ec in~ identification of criteria in advance of the remedial action. Ra:her the action.notes that the criteFia 'will be determined curing or after the remedial reply The staff stated that tnis approach by :he applicant does not provice for timely staff feedback at tne outset, but rather the staff must await '
ifresults of the they are program to determine what acceptance criteria-were used and acceptable. Thus, the remedial action is being conductec entirely at the applicant's own risk. .
The applicant's presentation of the permanen site dewa:ering system (presen-tation item 3.3) noted that the system is not. designed to seismic Category I requirements, but that the monitoring aspects of the system are safety grade.
.The NRC staff'noted that accep;ance criteria for the dewa:ering system are given in :ne Standard Review Plan (Section 2.4.13, Revisicn 1) and requested
" Safety Relatec that Permanen: rhe applicant address Branch Technical Posi:f on MS/GS31, The applicant will responc in the near future.Gewatering Sys ems", Revision 1, a::ach The quality assurance plan
' for. implementing the dewatering system will also be provided in future repcrts.
Bechtel describeo the structural and seismic analytical investigations :efng performed or planned for the affected s:ructures (f tem 4 of the presentations).
The staff noted that further review of the acceleration (g) value used for V]
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site design has been imcacted by staff manpower restructuring for the TM:-2 investigations and that use of outside contractors for the Midland seismic review is presently being considered. The staff also.noted that its presen: .;
I review indicates-seme areas of disagreement with the applicant's proposed l loads ccmbinations and design criteria for SSE and differentf al settlemen:,
and with the docut:5nt treatment these and otherofpositions cracks inatstructural a later date. walls. The staff will further Bechtel reported -(item 7 of the presenta:f ons)- the results of its investi-gations into the cause of insufficient compac f on of the plant area fill, and identified five causes considered to be the most proaable. The spoticant noted 'its agreement with the Secntel findings. Becntel noted tnat personnel were not included as a most precable cause because its review of qualifica:icns and exper.ience of both 3echtel and US Testing personnel nad snown presence of i
( sufficient education, experience, and training to carry cu: :ne tasks assigned.
The NRC staff noted that it dlsagrees with Secn:el's finding that perscnnel qualification was not a pecbable cause, and stated that further review of :he basis' for this Bechtel finding will be needed.
i Staff cements regarding the QA/QC aspects (presenta:f on i:em 3) were l
. based upon the applicant's 10 CFR 50.54(f) respenses :o question 1 :y l letter of April 24, 1979: l t
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. 1 Consumers Pcwer Ccmoany . . .- 9 0 0 6 :o m l l
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(1) The applicant's response in item 3.1 of Appendix I (page I-3) states i:s conclusion tnat " Specifications C-210 and C-21t previce sufficient criteria by wnicn to ensure taa: :he fill is adequately placed :o prevent excessive settlement." The staff. noted its disagreement with this statement. The rtaff noted, for example, that its' I&E investigations show : hat One specifica icns did not require qualification of equipment used to c mpact material One lift thicknesses permitted were excessive for acequa:e compa,c: ten, the meisture control was unclear and the compactive effort to develop 95% of ccmpaction was internally in conflice witnin Specification C-210.
(2) The applicant's response in item B.2 of Apcendix I (page I-3) noted that letters, I'd's, telecons, and :,emoranda are often used to clarify the intent of the specifications, and tha: i ;
is possible" that in some situations tne clarification proviced through such methods may have modifiec the specification withcut formally changing the wording of the specifica:icns. The s:aff cermented that a , ore positive statemen; appears to Oe warrantac cased upon the findings of I3E. Numer0us exampics where telecens and tremoranda were usec to change :he requirements of tne speci-fications without revising :he control?ec documen: 1:341f was cited in I&E Inspection Reper,. No. 50-329/78-20 and 50-330/73-20.
t TN 1 I&E found :nat not only did these memcranda cnange :he require-V ments of the specifications, but in some instances, conflicted with previous engineering directives.
(3) The staff noted that its review of QA as:ects was centinuing and that further requens for information would be issued.
At the conclusion of tne presentations, the NRC staff noted tha: :ne information presented was significant to :ne present review, and requested
' that the applicant document and submit its presentations, including c0 pies of the viewgraph slides used. .
. r W l/ Ash ~..: . h "
Darl Hecd,' Project Manager Lign: Wa:er Reactors Brancn No. 4 Oivision of Project Managemen:
Enclesure:
As stated cc: See next page u
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. t 6 INCLOSURE 1 .
ATi'ENDEES l
July 18, 1979 Censumers Pcwer comoany ' Sechtel* l l
G. S. Keeley .
T. E. Jonnson (BPC)
O. E. Horn- P. A. Martinez (BPC)
T; Thiruveneadam X. Wiedner (BPC)
T. C. Cooke D. Riat (AA)
W. R. Ferris (SF)
H. Wahl (AA)
NRC:NRR A. 8. Arnold (SF) -
S. Char (AA)
O. S. Hood F. J. Hsiu (AA)
O. M. Gillen S. S. Afifi (AA)
- 1. E. Lipinski G. Ricnardson (BPC)
J. Gilray A. J. Scos (BPC)
F. Schauer J. R' Cavie (G)
L. Heller L. S. Rubenstein Seentel Censulcants fm NRC:0ELO R. B. Peck (d
)
R. Hoefling R. Loughney C. H. Gould .
NRC:IE_
- 0. W. Hayes G. Gallagher
-J. 3. Henderson
. ACRS
- 0. Zukaar P. Tam l
!
G= Gaitnerscurg, Md. i u l e
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( RESPQ15E TO 0,EsrIOl 23, PAR:' (1) (50.54(f)}.
SECTIO! 1.0, NR: Q74:5TIOT 1
SUPPI-M REX 1'EST FCR ACOITIOGL SOIIS sra:1,Eyny:' DECFPMIOf
- 23. ,
W have revised ycur respense to question 1 cf cur March 21, 1979 letter' "10 CFR 50.54 Recuest Regading Plant till," inctPAing related c.ehts or
- supplements in p ar letters dated May 31, July 9, an:1 Ju.: gust 10, 1979, t'e
- find that the infcenaticn previded is net sufficient fer cc=pleticn of cur review. Accendingly, previde the felicvi.w additienal infecacicn
(1) a-Ycur resp:nse to questien la does net previde sufficient infematicm relative to the rect causes of the 13 deficiccies. In crder to deter. ira the acceptability cf corrective actions for the 13 deficiencies .
- xtsidering the ;cssibility that trase deficiencies are of a generic nature that could affect other areas of the facility, a
- :cre cc understarxiing of the rect cause of each deficiency is necessan.plete i- Accordingly, provide a clearer descripticn of the rect causes of each i
of the 13 deficiencies, including a detailed discussien cf the cerrfitiens that existed to allcw these deficiencies and tF4 changes that have teen made to preclude the recu=ence of such deficiencies. In this regad, l
if centributing causes are inadequ.ste precedures, inspecticns, specifi-D -
- cation call cuts, design reviews, audits, ard/cr technical directicn, (s
a clear ard detailed desc::ipticn is nessan as to 5 hat alled these c:nditiens to exist ard why.
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Revisien 4 23-1 11f79
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RESPCNSE TC QUESTICN 23, PART (1) (50.54(f)]
1 SECTICN 2.0, TNTRODUCTION ,
2.1. General Subseccions 3.1 through 3.13 of this Response to Question 23, Part (1) provide 'information supplementing our Responses to the NRC 10 CFR 50.54(f) Request Regarding J' *
' Plant Fill for Midland Plant Units 1 and 2, Consumers Power Company Docket Numbers 50-329 and 50-330, transmitted from CPCo (S.H. Howell) to the NRR (H.R. Denton) on ei April 24, 1979 and our presentation to the Staff given on July 18, 1979, in Bethesda, Marylan'd, and documented via cur transmittal from CPCo (S.H. Howell) to I&E *
(J.G. Keppler) on August 10, 1979. This introductica provides the rationale for determining the root cause of each of the 13. deficiencies identified through the investigations by the NRC, CPCo, and Bechtel; ccmments concerning the significance of the 13 deficiencies; and an sxplanation of the format used in addressing each deficiency.
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In arriving at the root cause, the following factors were considered.
1 a. The purpose of the quality assurance program is to ^
provide confidence that quality-related activities are' performed in a controlled manner such that the .
product conforms to the FSAR and design require-ments. .
- b. The control measures applicable to the performance of the quality-related tasks are.to provide sufficient direction and methodology to supplement the capability of the assigned personnel. '
- c. Personnel assigned the responsibility of performing
- the quality-related tasks are to have the required capability, knowledge, and skill (when supplemented i
by specifications, drawings, procedures, instructions, l and the prescribed control measures) to satisfactorily perform their assigned responsibilities.
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RESPCNSE TO QUESTION 23, PART (1).(50.54(!)]
- d. As the quality assurance program develops and is implemented, revisions or cor ections will be necessary tor-
- 1. Achieve the optimum balance or relationship between personnel capabilities and the prescribed
, control measures
)',
- 2. Accommodate unique or unplanaed events
.3. Incorporate related experience and state-of- er the-a rt improvemen ts .
The 13 deficiercies identified through invest'igations by Bechtel, CPCo, and the NRC are each addressed with the same intensive effort, irrespective of their contribution to the cause of the settlement. The relative contribution
, .that each deficiency made to the settlement can be qualitatively derived from Sections 7.0 (cause Investigation)
I and 8.0 (Ouality Assurance and Quality Control Aspects) of the documentation transmitted on August 10, 1979.
Essentially, this documentation pointed out tha t the most probable causes of the settlement were as follows: .
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- a. In some cases, lif t thickness exceed the capability of the equipment being used. This was shown by a the lift thickness /compactive effort tests conducted to qualify compaction. equipment prior to resuming I soils work. This indicates that the equipment was not adequately qualified.
- b. Reliance on soil test results, or on the evaluation l of the test results, provided a common mode failure l
. mechanism because:
1 i
- 1. Construction relied on test results, or on the evaluation of the test results, from inprogress placements for qualification of equipment during the work.
- 2. Quality Control depended on the results,.or on the evaluation of the results, of in-place soils tests for acceptance of the work. Associated with ,
this principal reliance, surveillance type
~
inspection procedures were applied to other
< soils work activit
. part of the time. y in the power bicek at least Therefore, deficiencies most closely associated with these two probable causes would bear the most
-s significant contribution to settlement.
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RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
2.2 De f initions The following information is provided .to achieve a l common understanding of the terms used and information !
included in Part (1) of this Response to Question 23. .
Title:
This identifies the information as being in response to the applicable part of Question 23 under j
10 CFR 50.54(f), transmitted from the NER ( L.S. Rubens tein) to CPCo (S.H. Howell) on September 11, 1979.
e~
De ficiency Desc r iption: This provides a restatement of the reported def teiency as originally stated in the CPCo response ref erenced below.
. I& E Re po r t Re f e re nce : This identifies the pages of Inspection Report 78-20 which bear upon the reported deficiency.
CPCo Re s po'n s e Re f e re nc e: This identifies the portion oc cne GFCo (5.H. Howell) letter to the NRR ( H. R. De n ton ) ,
Serial Howe-121-79, Appendix I, dated April 24, 1979, ,
f~s ,
which .provided the original response.
"\,,,/ Discussion: This provides background information
_ \ - relative to the reported deficiency as it relates to A the implementation of the Quality Assurance Program.
! Quality Assurance Program Criterion: This identifies, ey title, cne Quality Assurance Program criterion, listed in. Appendix B to 10 CFR 50, which is applicable to the reported deficiency and the identified root cause.
Program Element: This identifies the program element,
, governed oy tne criterion, which is applicable to the '
.n a reported deficiency' and the identified root cause.
Quality Assurance Program Policy: This identifies the Nuclear Quality Assurance Manual, Job 7220 section and number which define the related Quality Assurance Program Policy. The Manual identifies requirements 'and
. assigns respo'nsibility for developing and implementing control measures for performing related quality assurance -
activities.
. , Cont'rol Document: This identifies the current control
.,se e document developed and implemented by the organi:ations assigned the responsibility for performing the quality assurance activities under their cognizance.
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RESPCNSE TO QUESTION 23, PART (1)' (50.54 (f)]
Instructions, Procedures, and Drawings: This identifies tne instructaens, procedures, and drawings which are prepared to supplement the control documents when it is necessary to provide more specific direction and methodology.
This information is provided only when this level of
' subtier. document is pertinent to the deficiency being
.., , discussed. ,
Root Cause : This -identifies the root cause, for the reported deficiency described under "Disecssion." e-Remedial Action (Scils) : This describes the action's taxen or to ce taken as a result of the reported deficiency which are needed to assure that prior and future soil placements conforms to the quality require-ments defined in the FSAR and design documents.
Corrective Action (Procrammatic): This describes the actions taken or to ce taken to correct the root cause in the policies, procedures, and instructions in order to prevent recurrence of a similar type of deficiency.
['\s_j/') ' Corrective Action (Generic): This describes the actions ks taken or to be taken when root causes are potentially generic to work other than soils work. The actions are n
.to assure that the's' ame deficiencies do not exist or, if found to exist on completed work, are investigated
- - to the extent necessary ec assure that the work conforms to quality requirements defined in the FSAR and design documents and that the work quality is evidenced in the
., quality records.
In v'iew of your comments during our presentation to the NRC Staff on September 5, 1979 in Bethasda, Maryland, during which we presented some of this information,
. please note the added amphasis that we have placed en ccmmunicating both the programmatic and generic corrective actions.
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RESPCNSE TO QUESTION 23, PART (1) (50. 5 4 (f) ]
SECTION 3.0, DISCUSSION AND EVALUATION 3.1 Catecory I,. Item 1 Deficiency
Description:
Inconsistency between specifi-cations and tne Dames & Moore Report ISE-Report
Reference:
Pages 9, 10, 16, and 17 1, -
CPCo Response R'eference: Category I, Item 1 87 Discussion: A number of consultant reports were added to the PSAR as appendixes. The reports contained considerable and sometimes conflicting 1information.
Th'e information contained. in the consultant reports was subject to being misconstrued as commitments. The personnel who reviewed and provided input for the PSAR did not provide documented disposition of the Dames &
Moore Report reccmmendations to identify those recommen-dations which were PSAR commitments and those which were not,
, Quality Assurance Program Criterion: Design control N[ Program Element: Design input
.g Quality Assurance'Proeram Policy: Nuclear Quality Assurance Manual,Section II, Number 2, " Design Control Proced ur e " (April 1978) ; and Section II, Number 4,
" Design Criteria" (March 1974)
Control Document: Engineering Capartment Procedure 4.22, Revision 1, " Preparation and Ccatrol of SAR" (June 1974)
' Root Cause During the preparation and early revisions of the PSAR there were no procedural requirements or methods for documenting the disposition of consultant recommendations in the PSAR.
Remedial Action (S c il s') : ' The Dames & Moore Report was reviewed and raccmmendations were identified and dispo-sitioned. Dames & Moore recommendations which were.
included in the FSAR were unaffected by this review and no revisions to the FSAR were necessary as a result of this review. However, as a result of other activities, l , changes were made in design and construction dccuments L
which relate to some subjects covered in the Dames &
Moore Repcre.
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RESPONSE TO QUESTION 23, PART (1) (50.34(f)]
k Corrective Action ( Procramma tic) : Engineering has revised Engineering Department Procadure 4.22 to clarify 8 that Engineering personnel preparing the FSAR will follow the requirements of Regulatory Guide 1.70,
- Revision 2, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" (September 1975).
Specifically, Regulatory Guide 1.70 (Pages iv and v of the Introduction) requires that such consultant reports only be referenced with the applicable ecmmitments and
) supporting information included in the text (third paragraph, Page v). Such a requirement precludes repetition of this circumstance. '
'g Corrective Action (Generic): Consultant reports other than Dames & Moore were considered in accordance with the guidelines provided in NRC Regulatory Guide 1.70,
- Revision 2. Consultant reports were not attached to
'the FSAR, but portions of consultant reports were extracted and incorporated into the FSAR text itself.
Those ments.
portions incorporated into the FSAR become commit-Therefore, disposition of reccomendations in consulting reports has been adequately accounted for in the preparation of the FSAR.
verification that those portions, of consultant reports
. - de termined to be commitments and incorporated into the FSAR have been adequately reflected in project design .,
documents has been accomplished via the FSAR rereview lt0 program described in the response to Question 23,-
Part (2).
The two Bechtel QA audit findings reported in our April 24, 1979, response (Paragraph D.1, Page I-8) have been closed out. The results of this audit are being utilized in the FSAR control system study ccamitted to in Subsection 3.3 of this response to Part (1) .
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s RESPCNSE TO QUESTION 23, PART (1) [ 50. 5 4 (f) ]
3.2 Catecary I, item 2 Deficiency Descrietien: Lack of formal revisions of specifica:1ons to reflect clarification of specifi-cation requirements i ,, IEE Reecrt
Reference:
Pages 9 through 14 l CPCo Resconse
Reference:
Category I, Item 2 e~
Discussion: Interof fice memoranda, memoranda, telexes, TWXs,_etc were often used to clarify the intent of'the specifications. . It is possible that in seme situations the clarifications provided through these methods were interpreted by the user as modifying the specificatien without formally changing the wording of the specifi-cation.
Quality Assurance Procram Criterien: Design control Procram Element: Design change centrol
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Cuality Assurance Procram Policy: Nuclear Quality
( e-Assurance Manual,Section II, Number 5, " Design Process
( and Change Control" (June 1977) a Control Decument: Engineering Department Project
- Instrue lon 4.49.1, Revision 3, " Specification Change Notice" (May 1979)
Rect Cause: Prior'to Revision 2 (May 4, 1979), Engineering Department Proj ect Instruction 4.49.1 did not address the use of interoffice memoranda, memoranda, telexes, TWXs, etc which might be interpreted by the user as e, modifying the requirements of the specification.
Remedial Action (Scils): Applicable Specificatiens 7220-
' C-210 and 7220-C-211 were revised to incorporate interpreta-tions that af f ected specification requirements. The acceptability'of the ecmpleted work was independently detecnined by a subsequent subsurface investigation
.. p cgram. .
Corrective Actions (Procramma tic) :
o .
, . . 1. On April 3, 1979, Midland Project Engineering 3.* Group Supervisors in all disciplines were reinstructed tha: the only precedurally correct methods of )
Duplementing specification ch'anges are thrcugh the l use of specifica:icn revisier.s or Specifica ica
[ '\ Change Notices. This was fc110wed by an interoffice l
\ ,,) s. memorandum frem the Project Ingineer to all Engineering i Group Supervisers en April 12, 1979. l 23-3 Revision 4 2
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RESPONSE TO QUCSTION 23, PART (1) (50.54(f)]
- 2. Engineering Department Pro]ect Instruction 4.49.
was revised in Revision 2 to state, "Under no circumstances will interoffice memoranda, memoranda, telexes, TWXs, etc be used to change One requirements of a specification."
Corrective Action (Generic): A review of interoffice memoranda, menoranda, telexes, TWXs, and otner corres-pondence relating to specifications for construction and selected procurements of Q-Listed items will be initiated.
The purpose of the review will be to identify any clarifications which might reasonably nave been inter-preted as modifying a specification requirement and for which the specification itself was not formally changed.
An evaluation will be made to determine the effect on the technical acceptability, safety implications of the potential specification modification, and any work tnat has been or may be affected. If it is determined that the interpretation may have affected any completed work or future work, a formal enange will oe issued and I remedial action .necessary for product quality will be l taken in accordance with approved procedures.
The foregoing procedure will be followed for all specif1-cations applying to construction of Q-Listed items.
For specifications concerning the procurement of U-Listeu i t e ms , tuo foregoing procedure will be implemunted on a random sampling basis. The sample size has oeen estab-lished and tne specification selection nas been made.
Review and acceptance criteria for the specifications j have been defined.
The review of the initially selected prouurement specifi-l cations indicated tnat the acceptance critetia were not l met in one discipline. The review was expanded to 1004 i of the specifications in'that discipline (both construc-tion and procurement specifications), and for tne otner disciplines the sample of procurement speci t iuat to:.s I was increased to permit each discipline's review te ce I
evaluated individually.
This expanded review is scheduled to be completed uy June 5, 1901.
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RESPONSE TC QUESTICH 23, PART (1) . (50.54 (f) J l
3.3 Categcry I, Item 3
- . . Deficiency
Description:
Inconsistency of information l- witnin the FSAR relating to. diesel generator building l
fill material and settlement j -' It.E Report
Reference:
Pages 6 through 8 l CPCo Response'
Reference:
Category I, Item 3 I Discussient When the FSAR was prepared and reviewed, One major backfill operations were complete. There were no known inconsistencies or recent design document changes related to FSAR Subsections 2.5.4 and 3.8.5; therefore, these subsections were essentially inactive and were not subject to any further review. The incon-sistencies within the TSAR and between the FSAR and i design documents were not detected. The inconsistency between Subsections 2.5.4 and 3.8.5 with respect to the
! settlement. values resulted because the two subsections were prepared by separate organizations (Ceotechnical
[a)
- Services and Civil Engineering), neither of which were l
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aware of.the multiple display of similar information in the opposite subsection. The inconsistency between 3
.c TSAR Subsection 2'.5.4 and the project design drawing (Drawing 7220-C-45) with respect to the fill material resulted because 'at the time of FSAR preparation the
'Geotechnical Services personnel preparing the TSAR were unaware, in this case, of the status of the d= sign drawing prepared by Civil Engineering.
l~ ., Quality Assurance Program Criterion: Design control
'.f , Program Element: Design input Quality Assurance Program Policy: Nuclear Quality l
- Assurance Masual,Section II, Number 4, " Design Criteria" l (March 1974) .
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Control Documents: Engineering Department Procedure l- -
4.22, Revision 1, " Preparation and Control of Safety i' Analysis Reports" (June 1974); Engineering Department p project Instruction 4 25.1, Revi'sion 6, " Design Inter-
, face Control (In ternal) " (September 1979) ; and Engineering Department Project Instruction 4.1.1, Revision 0,
" Preparation of the Design Requirements Verification i
checklist" (July 1974) 1
- p. Root Cause: The control document did not provide t sufficient procedural centrol for preparation and V - review of the FSAR.
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' RESPONSE 'To QUESTION 23, PART (1) '50.5'4( f) .
l Remedial Action (Soils ): The inconsistencies between FSAR Suosections 2.5.4 and 3.8.5 have been corrected via. FSAR Revision 18 (February 28, 1979). The same revision also corrected the inconsistency between FSAR Subsection 2.5.4 and Design Drawing C-45. ,
Corrective Actions ( Programma tic):
- 1. A study was completed which examined current i
I.
l procedures and practices for the preparation and control of the FSAR in view of these experiences. m~
Procedural changes have been initiated by the revision l8 of or addition to the Engineering Department Pro-cedures. 8
- 2. To preclude any future inconsistencies between the
- FS AR and specifica tions, Engineering Department t Project Instru: tion 4.1.1- has been revised to state l8 L
- that.all specification changes, rather than just
" major changes," will be reviewed for' consistency l- with the FSAR. l 8-l l Corrective Action (Generic): FSAR sections have been
, [' rereviewed as discussed in the Response to Question 23, j $o Part (2).
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x .s RESPCNSE TO QUESTICN 23, PART (1) (50. 54 (f) ]
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3.4 ' Category :, Item 4 Deficiency ~0escriotion: . Inconsistency between basis
- for settlement esiculations for diesel generator
' building and design basis .
-I&E Report Reference Pages 20 and 21 CPCo Response
Reference:
]* j Category I,* Item 4 Discussion: The initial settlement calculations wero *~
performed by Geotechnical Services based on preliminary Onformation provided by Project Engineering. The final
.* diesel generator building foundation design configura-
- tion (as described in the FSAR) was different from the preliminary information. The originator of the final l
-design configuration did not interface with Geotechnical
(
Services to verify impact on final settlement calculations.
! It .was subsequently determined that the change in '
foundation design would have an insignificant effect en the calculation. However, no changes or notations to the original' calculations were made, thus resulting in I
- an inconsistency between the basis for settlement calculations and design basis.
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Quality-Assurance Program Criterion: Design control ^
Program Element
- Design coordination Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section II, Number 2, *0esign Control Procedures" (April 1978);Section II, Nu=her 9, "Cesign
' Interface" (March 1974); and Section II, Number 10, "Speciality Group Design Control" (June .1977)
Control occuments: Engineering Depart =ent Procedure 4.22, Revision 1,
- Preparation and Control of Safety i -
Analysis Reports" (June 1974); Engineering Department
!3* Project Instruction 4.25.1, Revision 6, " Design Inter- I l
' face Control (In ternal-) " (Septe=her 1979) ; Procedure o
T7-6437-1, " Design calculations" (January 1979); and Engineering. Department Procedure 4.37, Revision 2, ]
i - " Design Calculations" (May 1976). .
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v' '. 1. Diesel generator building foundatien desi n7 changes 1
- initiated by Project Engineering were ne ccordi-nated with Geotechnical Services, as required by l pr .
the Control documents.
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RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
- 2. Geotechnical Procedure FP-6437 did not require
' ' that the calculations show evidence of any evalua-tions for changes to input data, even when considered to be of ~no significance to the results.
Remedia1' Action (soils): Settlement calculations will -
ce revised af ter ene completion of the diesel generator building surcharge operation. . At that time, the design
' drawing will be coordinated with Geotechn'ical Services I- and any changes or notations needed to reflect design changes will be made. ,
4 Corrective Actions (Programmatic):
14 An interoffice memorandam dated April 12, 1979, was issued by Geotechnical Services to alert personnel of the need to revise or annotate -
calculations to reflec~t current design status.
- 2. In view of. the above, Geotechnical Services has revised Procedure FP-6437 to require that 8 calculations be annotated to reflect current
- design status.
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- 3. Engineering Department Procedure 4.37 has also been
~
revised to require that calculations be annotated to g2 reflect current design status. ,
Corrective Action (Generic): This is considered an isolated case-and not generic based on Quality Assurance audits of Geotechnical Services conducted in February and August.1979. The results of these audits indicate that this area is effectively controlled. Quality Engineering surveys tand Quality Assurance monitorings will verify future coordination of design documents by Geotechnical Services and Project Engineering. ,
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u RESPCNSE TO QUESTICN 23, PART (1) (50. 54 ( f) ]
3.5 Ca tego ry I, Item 5
,_ De ficiency Descriotion: Inadequate design coordination in ene design-of the duct' bank I&E Reoort
Reference:
Pages 23 and 24 CPCo Reseense
Reference:
Category I, Item 5 1' Discussion: Tour vertical duct banks were designed and constructed without sufficient clearance to allow for relative vertical movement between the duct banks and .-
the building footings. Civil Drawings 7220-C-1001 and 7220-C-1002 (which show the footing requirements) were coordinated with Electrical Drawing 7220-E-502 (which shows the duct bank stub-up location and dimensions),
as required by Engineering Department Procedure 4.46 and Engineering Department Project Instruction 4.25.1. .
Drawing 7220-E-502 refers to Drawing.7220-E-543, which
' shows a minimum size for the underground duct bank some distance away from the stub-up. Neither electrical nor I civil drawings show how or where to accomplish the transition from the stub-up size to the underground i
duct size, nor do they show firm definition of duct
! size. The transition and final size of each; duct were l [N)*
( established by the Field Engineers during construction.
l The civil design was based on the stub-up dimensions A-
.shown in Drawing 7220-E-502, and did not acknowledge that the duct bank size under the slab and/or footing was to be determined by Tield Engineering.
Qua'lity Assurance Program Criterion: Instructions, procedures, and drawings Procram Element: Preparation of drawings Quality Assurance Procram Policy: Nuclear Quality Assurance Manual,Section II, Number 2, " Design Control I
9 Procedures" (April 1978); and Section II, Number 9, g
" Design Interface" (March 1974)
Control Documents: Engineering Department Procedure l
4.46, Revision 3, " Project Drawings" (May 1976) and Engineering Department Project Instruction 4.25.1, Revision 6, " Design Interface Control (In ternal) " , '
(September 1979) l Instructions, Procedures, and Drawings: Electrical i Standard Detail Drawings and Civil Standard Detail
}. Drawings I
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O RESPONSE TO QUESTION 23, PAST (1) 150.54(f)1
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Root- Cause: Failure of the drawings to provide Construction witn ene information necessary to prevent interference, Remedial Actions (Soils):
- 1. Provisions were made to allow independent vertical movement between the diesel generator building and the duct ba nks .
~
/ 2. Bech tel Project Engineering has reviewed the design drawings for cases where ducts interf ace with structures to determine the possibility of .
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the duct being enlarged over the design reqcirements and the effect this enlargement may have upon the structures' behavior. Forty-four individual or groups of similar buried electrical duct banks were reviewed. The terminations of each case were reviewed, resulting in the identification of 23 questionable vertical interfaces. Based on geome try, depth of vertical leg, and whether sufficient i
details were available on the design drawing, 11
(
cases were identified for detailed investigation.
Additional information was obtained from the i_(N) .
jobsite to define how the interf ace was cons tructed g and whether any unusual behavior existed.
The. review concluded that several nonsafety-l related transformer pads experiencing differential .
i
' settlement may be exaggerated by the duct bank l interface. However, in no case except the diesel generator building has settlement been completely res tricted or do details, geometry, er subgrade conditions indicate that settlement would be j completely restricted.
Corrective Actions (Programmatic): -
1 l 1. Civil / Structural cesign Criteria 7220-C-501 has been modified to contain the requirement tha t a duct to bank penetration shall be designed to eliminate the possibility of the nonspecific size duct interacting with the structures. l 10
- 2. The civil standard detail drawings have been revised {8 to include a detail showing horizontal and vertical
, clearance requirements for duct bank penetrations.
The detail addresses any mud mat restrictions. 8 23-15 Revisien 10 11/80 e
m , . - . . - - - ,e, ~ - - - - , , - m w w+,,c-,- - - , . - - , , .-c, y-- , , . - , y. y -
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RESPONSE TO QUESTkCN 23, PART (1) ( 50. 54 (f) ]
Corrective Action (Generic) : This condition is not considered generic, cut ra:her an anomaly unique. to electrical duct banks. The uniqueness arises from che practice of not pinpointing the si:e or location of the duct bank on the drawings and leaving it'to be established during construction.
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23-16 Revisien 4 11/79
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>- G / RESPCNSE' jo OUES;ICN. 23, PART (1) (50.54(f))
3.6 Category II, Iten 1 ceficiency
Description:
Insufficient compactive effort used in eacxtaAA operation-
. I&E Report
Reference:
Not applicable CPCo Roseense
Reference:
Category II, Item 1
.)* Discussion: Specifications-7220-C-210 and 7220-C-211 specified requirements for selection and approval of compaction equipment on'the basis of demonstration. . e.
The equipment was used on the basis of achieving either satisf actory in-place test results or satisf actory evaluation of the test results. There were no field control documents or procedures to define requirements for
- the qualification of soils compaction equipment. There were no control documents to- govern the requirements for control measures pertaining to soils placement and compaction. . Construction and Quality Control relied on in-place . soil , test results , or on the evaluation of these results, to determine the acceptability of placement
,and compaction activities. These soil test results or ,
their evaluations were in error in numerous cases.
ouality Assurance Program Criterion: Instructions, procedures, and drawings 6 Program Element: Preparation of instructions, procedures, -
and drawings Ouality Assurance Procram Policy: Nuclear-Quality Assurance Manual,Section IV, Number 1, " Construction Site Quality Program" (April 1978); and Section V, Number 13, " Procedure
. Control" (June 1977)
Contro'1 occument: . Field Proce' dure FPG-1.000, " Initiating and-Processing Field Procedures, instructions, and Specifications" (January 1979)
Instructions, Procedures, and Crawines: Field Instruction
- FIC 1.100, Revision 0, aQ-Listed Sotis Placement Joe Responsibilities Matrix" (July 1979) 1 Root Causes:
1
, 1. Reliance was placed on in-place test results, or on !
the evaluation of the test results, for evaluating compaction equipment. Satisfactory soil test results, or evaluations of test results, impliet' tha t adequate compactive effort was obtained and equipment capability and fill placement methods were not questioned.
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(Incorrect soils test results are addressed in l Subsection 3.10.) ,
j Revision 4 i -
23-17 11/79 l
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l %s RESPONSE TO,QUESTIO 23, PART (1) ( 5 0 . ~54 ( f ) ]
-F l 2. The -Quality Assurance Program requirement to l
' establish responsibility for measures to control the placement. and compaction of soils and the i-qualification of construction equipment was not l adequa tely impl'emented.-
~
1
' Remedial' Actions (Soils):
- 1. Compaction equipment currently in use has bee'n
.l qualified and Construction has been notified of the parameters governing the use of the equipment.
l 2.
. .r.
l Project- Quality Control Ins truction (PQCI) C-1.02 I was revised to include _ verification of the use of qualified equipment and compliance'with qualified procedures.
' Corrective Actions (Programmatic):
- 1. Field Ins truction FIC 1.100, "O-Listed Soils-Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for performing soils placement 'and compaction.
/j ' 2. Field Instruction 1.100 has been supplemented by 18 l ( f es tablishing requirements for demonstrating equipment i
( capability, including responsibility for equipment ^
' approval, and providing records identifying this
' capabili ty. 18 9
- 3. Quality Assurance has issued a Nuclear Quality ;jo Assurance Manual- amendment to clarify the -requirement i
that procedures include measures for qualifying
!- equipment under specified conditions. \10
- 4. Engineering clarified specifications and construction prepared procedures (governing the soils compaction 10 i ,
eq uipme nt ) to implement the requirements of the Nuclear Quality Assurance Manual as stated in Item 3 8 (above). 1 10 Corrective Action (Generic): Construction specifications, i ins tructions , and procedures were reviewed to identify any other equipment requiring qualification which has .
not yet .been qualified. No such equipment .vas identified.
i O) t V- 23-18 Revision 10 i
11/80 t
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- U RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
3.7 ' Ca t ec o ry II , Item 2 Ceficiency
Description:
Insufficient technical direction in ene field I& E Report References Pages 24 through 25 l ..,, CPCo Response
Reference:
Category II, Item 2 -
l .
Discussion: The Dames & Moore Report and Civil / Structural cesign cetteria 7220-C-501 state, in part, " Filling .-
operations shall be performed under the technical supe rvision of a qualified Soils Engineer. . . . " The technical direction and supervision were provided by Field Engineers and Supervisors who were assigned the responsibility for soils placement. The technica.1 i direction and supervision provided were not properly l deployed to overcome the lack of documented instructions n
and procedural controls. Reliance on test results, or l h on the . evaluations of test results, .did not identify j the need for additional direction and supervision.
i
,4s Field Procedure FPG 3.000, " Job Responsibilities of
'(
- Field Engineers, Superintendents, and Field Subcontract
\s_ Engineers," was not intended to provide instructions for the performance of, specific tasks and functions. s Ouality Assurance Program Criterion: In s t ruc t io n s ,
procecures, and crawings Program Element: Preparation of instructions, procedures, 4
ano. drawings Ouality Assurance Program Policy: Nuclear Cuality
! Assurance Manual, 'section IV, Number 1, " Construction Site Quality Program" (April 1978); and Section V, Number 13, " Procedure Control" (June 1977) l Control Document: Field Procedure FPG 3.000, " Job
( Responsicilities of Field Engineers, Superintendents, and Field Subcontract Engineers" (Cctober 1977)
In s t ruc t io n s", Procedures, and Drawings : None Root Cause Reliance on test results, or on the evaluations
, of test results, and surveillance by Ouality Centrol instead of'providing sufficient technical direction through documented instructions and procedural controls.
(Incorrect Soil Test Results are addressed in Subsection 3.10).
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'23-19 Revision 4 l 11/79 a.. . . . - - , . . . . . . , . _ - . - -- . . - . _ , . - . _ . , - . - . -
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RESPONSE TO QUESTION 23, PART (1) (50. 54( f)]
Remedial Action ( Soils): One fulltime and one parttime onsite Geotecnnical So11s Engineer have been assigned, These engineers provide technical d4 'etion and monitoring of the process.
Corrective Action (Programma tic): Field Instruction FIC 1.100, " Q-Listed Soils Placement Job Responsibilities
, Matrix," has been prepared and establishes responsibilities y' for performing soils placement and compaction.
Corrective Action (Generic): Design documents, instructions, ,~
and procedures for those activites requiring inprocess con-trols will be reviewed to assess the adequacy of existing procedural controls and technical direction. Engineer-ing review has been completed, and Field Engineering and Quality Control review is scheduled for completion by to February 27, 1981. Any revisions required will be com-pleted by April 17, 1981.
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V'\.. - Revision 10 23-20 tijgo v v. ,o + , , , -3 .rw .c,,-_,-rm-_. ,-,.,--3S.,e-. .,m,..,vme.., ~~-w..---.- w- , ,_,.,w,,, , ,%.,_r.r..,,-w,e._, .,. ,, ,- ,.w-- ,--
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RESPONSC TO QUESTION 23, PART (1) (50.54(!)1 i
3.8 Catecoey III, Item 1.
I ceficiency cese~ription: Inadequate Quality Control Inspection of placement of fill Ist Recort
Reference:
Pages 25 through 29 l '.. CPCo Response
Reference:
Category III, Item 1 l
Discussion: The Nuclear Quality Assurance Manual l' requires chat Construction Quality Control Procedures "'
" define the method for indirect control by monitoring-l of precessing methods, equipment, and personnel, when inspection of processed items is impossible or disadvantageous."
l Control Document SP/ PSP G-6.1, " Quality Control Inspection Plans,* does not adequately include ce reference this
' requirement in the instructions for preparation of Quality Control Instructions.- Quality Control Instruction l
PQCI C-1.02 did not adequately satisfy this require.nent.
' The inspection of soils was accomplished by "survvillance,"
and did not require ' verification of the con *.rols specified e~st in Specifications 7220-C-210 and 7220-C-211. Soil test j- \
results, or the ovaluations of soil test results, were l
\s_ / used as the basis for quality-verification.
L ,\ Quality Assurance Procram Criterion:
l Inspection instructions, procedures, and drawings .
i Procram Element: Establishment of an inspection program, documented instructions and procedures for accomplishing the inspection activity, and the preparation of instructions and procedures Cuality Assurance Procram Policy: Nuclear Quality- -
Assurance Manual,Section IV, Number 5, "Pield Inspection and Test" (June 1977) 1 Control tecument: SF/ PSP G-6.1, Revision 4, " Quality Control Inspection Plans"_ (January 1973).
Instructions, Procedures, and crawines: PCC I C-1. 0 2, Revtston 4,
- Compacted Sackft11* (July 1979) 5 Roo t - Ca use s :
'1. Control Document SP/ PSP G-6.1 does not include i
sufficient specificity in its requirements for the preparation, of inspection instructions.
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23-21 11/79 6
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- RESPONSE TO QUESTION 23, PART (1) (50.54(f))
- 2. Too much reliance was placed on the Quality Control Inspector's abili ty, wi thou t sufficiently specific inspection instructions.
- 3. Reliance was placed on soll test results, or on the evaluation of soil test results, which were in error in numerous cases. (Incorrect Soil Test Results are addressed in Subsection 3.10.)
}
_ Remedial Actions (Scils):
- 1. e-PQCI C-1.02 has been revised to incorporate the.
specific characteristics to be verified by Quality Control.
- 2. An in-depth soils inves tigation program, which was implemented as described in our prior transmittals, provides verification of the acceptability of the soils or identifies any nonconformances requiring further remedial action.
Correct ive Act ion ( Procramma tic): Control Document
/
' ' SF/ PSP G-6.1 nas been revised to provide requirements 110 for inspection planning specificity and for the utili-(
- )( zation of scientific sampling rather than percentage sampling.
l10 Corrective Actions (Generie)
- 1. QCIs in use will be reviewed to ascertain that provisions have been inc'luded consistent with the revised control document. This action and any required revisions are scheduled to be completed l by April 17, 1981.
{10 l 2. The impact of Corrective Action Item 1 (above) on I
completed work will be evaluated, and appropriate actions will be taken as necessary. This action is scheduled to be completed by. April 17, 1981. l10 23-22 Revision 10
{ 11/80
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RESPCHSE TO QUESTION 23, PART (1) (50. 54 (f) ]
3.9 Category III, Item 2 Deficiency Cescription: Inadequate soll moisture testing .
I&E Report
Reference:
Pages 14 through 16 CPCo Resconse
Reference:
Category III, Item 2
- 1. . _
Discussion: Prior to 1978, moisture-content was controlled S'y: tests performed 'af ter compaction. Few or no tests ,. '
were performed Specification 7220-C-210, on the fill during Sectioncompaction, 12.6. "During as required by-compaction" was interpreted by personnel in the field as the entire i process of $ lacing, compacting, and testing. The moisture content was measured during the density test, which was performed immediately after compaction.
Reconditioning was done after testing.
Quality Assurance Program Criterion: Inspection instructions, I
procedures, and drawings
-rw $ Program Element:
Est'ablishment of an inspection program, f.
4 the documented instructions and procedures for accomplishing the inspection activity, and the preparation of instructions and pro'cedures - .y I.
Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section IV, Number 5, "Tield Inspection and Test" (June 1977)
Control Document: SF/ PSP G-6.1, Revision 4,
- Quality Control Inspection Plans" (January 19 78),
Instructions, Proceduras, and Drawings: PQCI, C-1.02, Revision 4, " Compacted Backfill" (July 1979)
Root causes:
- 1. Control occument, $?/ PSP G-6.1 does not require i
i sufficient specificity for establishing an inspection
- program and for the preparation of inspection
, instructions. -
- 2. Reliance was placed on the informal incorrect
.# interpretations of the specification relative to
' moisture testing. This is discussed in Subsection 3.2.
- 3. Reliance was placed on Quality Control surveillances ex '
of meisture testing.
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23-23 Revision 4 o . ,
11/79 e
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\~ RESPONSE TO QUESTION 23, PART (1) (50.54(fil
- 4. Reliance was placed on the incorrect results of i the density tests, or on the ine'e rrect evaluation 1 l' of the.results, to the exclusion of the moisture tes t results. (Incorrect Soil Test Results are addressed in Subsection 3.10) .
- l. '
Remedial Actions (Scils):
. 1. .The specifications were revised to provide more J. definitive requirements for soil moisture testing.
- 2. PCCI C-1.02 was revised to provide specific inspection *"
. requirements for verifying soil moisture content, rather an surveillance. ,
- 3. Field ins truction FIC 1.000, "Q-Lis ted Soils ,
Placement Job Responsibility Matrix," has been I prepared, and establishes responsibilities for performing soils placement and compaction.
Corrective Actions (Procrammatic): !
- 1. Control Document SF/ PSP G-6.1 has been revised to l10 p -
. provide requirements for inspection planning I specificity and for the utilization of ' scientific
\
sampling rather than percentage sampling. (10 2.' Engineering Department Project Instruction 4. 49.1, Revision 3 now states, "Under no circumstances j
,1 will interof fice memoranda, memoranda, telexes, '
, TWXsi etc be used to change the requirements of a s pe ci f ica tio n. " This will provide controlled and uniform interpretation of specification requirements.
- 3. On April 3, 1979, Midland Project Engineering Group Supervisors in all disciplines were reinstructed that the only procedurally correct me thods of f
implementing specification changes are through the use of specification revisions or Specification.
. Change Notices. This was followed by an interof fice memorandum from the Project Engineer to all Engineer-ing Group Supervisors on April 12, 1979.
5(_jlk' i
'13-24 Revision 10 l 12/S0
- ~
hs RESPONSU TO QUESTION 2J, PART (1) (50.54(f)]
Corrective Actions (Generic;:
1.
QCIs in use will be reviewed to ascertain tnat provisions have been included consistent witn t.ie revised control document. This action and any required revisions are scheduled to be completed by April 17, 1981.
- 2. The impact of Corrective Action Item 1 (acove) on completed work will oe evaluated, and appropriate ;
actions will be taken as necessary. This action is scheduled to be completed oy April 17, 1981.
- 3. A review of interoffice memoranda, memoranda, telexes, TWXs, and otner correspondence relating to specifications for construction and selected procutements of Q-Listed items will ce initiated.
The purpose of the review will ce to identify any clarifications wnich mignt reasonaoly nave oeen interpre ted as modifying a specification requirement and for which the specification itself was not formally changed. An evaluation will be made to determine the ef fect on tne technical acceptauility,
' , s_? safety implications of the potential specification
/ modification, and any work enat nas been or may oe
~
affected. If it is determined that the inter-pretation may have affected any completed or future work, a formal change will oe issued and remedial action necessary for product quality will be taken in accordance with approved procedures.
The foregoing procedure will be followed for all specifications applying to construction for Q-Liated i t e ms .
For specifications concerning the procurement of Q-Listed items, tne foregoing procedure has been implemented on a random sampling uasis, fue sample size has been established and the specification selection has been made.
Review and acceptance criteria for tne spac.ficet tens nave ueen defined.
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I RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
The review of the initially selected procurecer t :ct-fications indicated tnat .ie acceptance criter14 w -re not met in one disciplin,. The review was expanueo to 100s of tne specifications in tnat discipline ( uu ta construction and procurement speci ieations), and ive the other disciplines the sample of procurement specifi-cations was increased to permit each discipline's re-view to oe evaluated individually.
This expanded review is seneduled to be completed oy June 5, 1981.
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' 1 RESPCNSE - To QUESTION 23, PART (1) 150. 54 ( f)I
\) - l 3.10 Ca tegory III, I ten 3 !
Deficiency
Description:
Incorrec t soil' tes t resul ts I&E Recort
Reference:
Not applicable
, CPCo Response
Reference:
Category I!!, Item 3 -
)' Discussion:
ena c some A review of soils tes t reports indicates tes t reports contain errors and inconsis tencies in da ta. Surveillance and tes t report reviews did no t
- identify these errors and inconsis tencies. The Quality Control surveillance and review included s teps to verify tha t the tes t results were reported as ei ther percent compaction or relative densi ty, as appropriate; that specification requirements for compaction and mois ture content were within specified limi ts and that the report form was properly completed and contained the required da ta and au thorited signa ture. This was in accordance with the requirements of Quality Control Ins truc tion 7 220-SC-1.05, " Material Tes ting Labora tories ,"
(j
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which includes ins tructions for monitoring the performance of verifica tion tes ting performed by the tes ting laboratory.
v Quali ty Assurance Program Cri terion: Control of purchased
( }' material,. equipment, and services (subcon trac tors) 3 Program Element:
per tormanc e Surveillance of the subcontractor's Quality Assurar.ce Program Policy: Nuclear Quality Assurance blanual,Section IV, Number 11, "Tield Subcon-trac tor' Control" (June 1977) ; and Section IV, Number 5,
, " Field Inspection and Tes t" (June 1977)
Control Document: SF/ PSP G-9.1, Revision 1, "Co ntrol l or Succontrac tor Work" (July 1977)
Ins truc tions , Precedures , and Drawines: Quality Control Ins truc tions 7 220-SC-1. 05, "Ma terial Tes ting Services" (October 1977)
Root Cause: Technical procedures available to control-ene tes ting were inadequate, and the technical direction of the tes ting opera tions did not avoid or detect the incorrect soil tes t results.
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l 23-26 Revisien 4 1
11/79
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RESPCNSE TO QUESTION 23, PART (1; (50.54(f)]
Remedial Actions ( Soils ):
- 1. Geotechnical Services has completed an investigation which includes an in-depth review of testing performed by U.S. Testing and the reported test
, , results. The purpose of this investigation was to identify the type of testing errors which were made in order-to facilitate analysis by U.S.
Testing and to accomplish Programmatic Corrective Action (below) and Remedial Action Item.2 (below).
- 2. Based on Item 1 above, the requirements for the i
control of testing were adjusted, requiring the
Tes ting Subcontractor to check all field density tests for cohesive material against 'd ze ro-a i r-voids curve. A specification change has been issued. Selection of proctor curves will no longer be a problem because each field density test will be accompanied by a separate laboratory standard which wi11 ' provide a direct comparison.
. This was directed by. a letter to U.S. Tes ting and reflected in Specification Change Notice C-208-9004, dated April 13, 1979.
)'
- 3. PQCI-SC-1.05 was revised to add more stringent
(, requirements for in-process inspection of U.S. ,
, Testing's soil testing activities.
. 6
- 4. An in-depth soils investigation program which was L
! implemented as described in our prior transmittals, provides verification of the acceptability of the soils or identifies any nonconformances requiring
- further remedial action. This action is identical to' Remedial Action Item 2 in Subsection 3.8.
Corrective Action (Procramma tic): Guidelines for surveillance of testing operations have been developed 18 i .
and included in Field Instructions for the ensite Soils Engineer. Engineering /Geotechnical Services has developed the guidelines, and Field Engineering .
B has prepared the instructions.
4 Corrective Actions (Generic):
} 1. U.S. Testing was required to demonstrate to cogni-
.; = ant Engineering Representatives that testing $o i
t procedures, equipment, and personnel used for l
j 23_27 -
Revisien 10
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l l
RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
' quality verification testing (for other than NDE and soils) were capable of providing accurata l 10 i test results in accordance with the requirements of appli' cable design documents. 110
- 2. A' sampling of U.S. Testi.ng's tes t reports ( for other than NDE and soils) were reviewed by cognizant go Engineering Representatives to ascertain that results
.. evidence confonnance to tes ting requirements and
)! design document limits. j10
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- RESPONSE TO QUESTICN 23, PART (1) (50.54(f)J 3.'11 Catecory III, Item 4
, ceficiency Cescri= tion: Inadequate subcontractor test procedures
, I& E Reoort
Reference:
Not applicable CPCo Resconse
Reference:
Category III, Item 4 e-Discussion: The procedures used for soils testing did ' '
not cover the following activities:
- 1. Developing and updating the family of proctor curves;
- 2. Visually selecting the proper proctor curves:
- 3. Developing additional proctor curves for changing materials occurring between normal frequency i
curves; and i
- 4.
i l I Using alternative methods of determining the proper laboratory maximum density where visual
, comparison is not adequate. a Bechtel Specification 7220-G-22, Revision 1 (June 22, 1973) is an attachment to Specification 7220-C-208 and l specifies the requirements for instructions, procedures, and drawings. These technical peccedures were not prepared.
l Ouality Assurance Procram Criterion: Control of purchased 1
material, equipment, and services .(subcontractor)
Precram Element: Control of supplier-generated (subcontractor-generated) documents Quality Assurance Procram Policy: Nuclear Quality Assurance Manual,Section III, Number 9, " Supplier Cocument Review" (June 1977); and Section IV, Number 11, " Field Subcontractor Control" (June 1977) '
- Control *ccument: SF/ PSP G-9.1, Revision 1, " Control
, o" Subcontractor Work" (July 1977)
Instructions, Procedures, and Crawines: Quality Control Instructions 7220/SC-1.05, " Material Testing Services" (Cetober' 1977)
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Rovision 4 23-29 11/79
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RESPONSE TO QUESTION 23, PART (1) [50.54(f)1 Root Cause: Adequate technical procecures for' control of the testing were not prepared.
Remedial Actions (Soils):
- 1. Geotechnicalhervicesnascompleted'aninvestiga-tion'which includes an in-depth review of *esting performed by U.S. Testing and the reported test results. The purpose of this investigation was to identify the type of testing errors which were made in order to facilitate analysis by U.S.
Testing and accomplish Remedial Action Item 2.
- 2. Based on Item 1 above, the requirements. for the control of testing. were adjusted requiring the Testing Subcontractor to check all fiela density tests for cohesive. material against a zero-air-voids curve. A specification change has been issued. Selection of proctor curves will no longer be a problem because each field density test for cohesive material (unless otherwise directed by the onsite geotechnical soils engi-neer) will be accompanied by a separate lacora-tory standard which will provide a direct com-parison. This was directed by a letter to U.S.
Testing and reflects Specification Cnange Notice C-208-9004, dated April 13, 1979.
- 3. One full-time and one part-time onsite Geotechnical Soils Engineer have been assigned. These engineers will review U.S. Testing's procedures and monitor their implementation.
Corrective Action (Procrammatic): Field Instruction FIC 1.100, "Q-Listed soils Placement Job Responsibilittes Matrix," has been prepared and establishes responstbilities for performing surveillance of testing operations.
Corrective Actions (Generic):
(
- 1. Design documents, instructions, and proceuures cor l
enose activities requiring inprocess controls util be reviewed to assess tne adequacy of existing procedural controls and technical direction.
Engineering review has ceen completed, and Field Engineering and Quality Control review is schedulaa for completion oy February 27, 1981. Any revistons required will ce completed oy April 17, l'>dl.
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V 23-30 Revision 11 2/dt
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RESPONSE TO QUESTION 23, PART (1) (50.54(f)] I
- 2. U.S. Tes ting was required to demonstrate to cogni- to zant Engineering Representatives that testing procedures,' equipment, and personnel used for quality verification testing (for other than NDE and soils) were. capable of providing accurate tast l10 results in accordance with the requirements of applicable design documents. [ 10
- 3. A sampling of U.S. Testing's test reports (for other l'
than NDE and soils) were reviewed by cognizant 10 Engineering Representatives to ascertain that ,g. ,
results evidence conformance to testing requirements ~
and design document limits.
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b L, 23-31 Revision 10 11/30
- v t o * + +- w e e v~e + - * , w *re ~w--,-,r*,ve--- - -em. e w a w-,--,r-,--,*,w, ,wr, w w - w - a e w w y, we e e www+ w r ee -v e <= w ww =w e-v=-wee ee-,. w,--re---= + w m.- ww -ww *--==-we- --
l l
l RESPONSE TO QUESTION 23, PART (1) 150.54(f)1 3.12 Ca t eco ry IV , Item 1 Deficiency
Description:
Inadequate corrective action for repe titive~ nonconforming conditions I&E Report
Reference:
Pages 17 through 20
, CPCo Response Reference Category IV, Item 1
)' Discussion: There were nonconformances reported which are considered to be repetitive. These include, but are not limited to: CPCo Nonconformance Reports QF-29, *~
QF-52, QF-68, QF-120, QF-130, QF-147, QF-172, QF-174, CF-199, and QF-203; CPCo Audit Findings F-77-21 and F-77-32; and Bechtel Nonconformance Reports 421, 686, 698, and 1005.
The Nuclear Quality Assurance Manual,Section V, Number 10, states in Subparagraph 2.5.2, "Nonconformances which, l 10 due to their repe tition or impact (potential or actual) upon quality, should be brought to management's attention for special action."
l Quality Assurance Department Procedure C-101, . Revision 1,
" Project Quality Assurance Trend Analysis" (July 1977)
A.
states in Paragraph 1.0, "This procedure provides a mechanism for identifying quality trends and initiating ^
i corrective action to prevent recurrence...." The
- reviews made in accordance with this procedure did not identify the significance of the repetitive nature of the nonconformances and the need for special action beyond that for the individual reports.
Control Document SP/ PSP G-3.2 defines the requirements for review of Management Corrective Action Requests (MCARs).
Quality Assurance Procram Criterion: Corrective action Procram Element: Actions partaining to significant conot tions adverse to quali ty Quali ty Assurance Procram Policy: Nuclear Quality Assurance Manual,Section V, Numbe r 10, " Management Corrective Action" (March 1979)
Control Documents: SF/ PSP G-3.2, Revision 5, " Control of Nonconforming Items" (September 1979) and QADP C-101, Revision 1, " Project Quality Assurance Trend l An alys is" (July 1977) l l
l -
\' 23-32 Revision 10 11/30 l
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- RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
j Root Causes:
1 1.
4 The conditions under which nonconformances are considered to be repetitive are not adequately
. de. fined in the control documents.
- 2. The trending activity did not provide timely responses t
to repetitive product nonconforming conditions.
i / Remedial Action (Soils): Not applicable Correct ive Action ( Procramma tic) : Control documents have oeen revised to provide an improved definition of 7" 110 implementing requirements for identifying repetitive non-conforming conditions. This action has been com-pleted for QADP C-101. Action for SF/ PSP G-3.2 has i also been completed. 10 Corrective Action (Generic): Consistent with the
-j intent of the programma tic change above, Quality Assurance
. will review nonconformance reports which were open, as- 10 of November 13, 1979, or became open prior to implemen-tation of the improved Project Quality Assurance Trend
(N s
Analysis program as stated above. This review will be to identify any- repetitive nonconforming conditions pertaining N '
i 8
Y to product type or activity, or pertaining to nonconformance
' cause. This action is scheduled to be completed by December ,
't 31, 1980.
i 6
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23-33 Revision 10 11/B0 9
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- arsPcNsz To QUESTION 23, PART (1) (50.54(f)]
' l 3.13 Catecorv,IV, Item 2 , l
. De ficiency
Description:
Bechtel- Cuality Assurance
' audicAng and monttoring did.not identify the problems relating to the settlement. This lack of identification of problems by the auditing and monitorinq ! contributed ;
' to a conclusion that soils operations were adequately '
controlled.
l :.
I& E Recort Reference ~ Pages 17 through 20 CPCo Response Reference Category IV, Item J Discussion: Quality Assurance auditing and monitoring is aAmed at evaluating the adequacy of policies and ' ;.
procedures and evaluating the degree of compliance with the policies and procedures. It is not a quality verification activity,. although it may identify deficiencies in the performance of quality-related activities that could result in unsatis f actory product quality. In the case of sells' operations, Opality Assurance auditing and monitoring found that quality-related activities 1 .
were being performed as planned, quality verification
\
activities (primarily soil testing) were being performed, and the soil test results, or their evaluation, provided evidence of compliance with the established standards. 4 The' auditing and monitoring did not identify the policy and procedure inadequacies.
Quality Assurance Procram Criterion: Auditing Procram Element: Auditing Quality Assurance Procram Policy: Nuclear Quality Assurance Manual,Section VI, Number 1, " Quality Audit System" (March 1979)
, !' Centrol Documents:. Quality Assurance Cepartment Procedure, L
Section.C, Numoer 1, " Project Quality Monitoring" (September 1977); and Section C, Number 5, " Project Quality Audits" (September 1977)
Root Cause: Quality Assurance audit and monitoring was -
oriented mere toward evaluating the degree of compliance with established procedures rather than toward the assessment of policy and procedural adequacy or toward l' the assessment of product quality.
m Revision 4
'A s> 11/79 23,-34 b
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l s' 1 RESPONSE M QUESTION 23, PART (1) (50.54(f)]
Corrective Action (Generic): The Quality Assurance audit and monitoring program will be revised to emphasize and increase attention to the need for evaluating !
policy and procedural adequacy and assessment of product quali ty A specialized audit training program will be developed and implemented to ensure guidance for this revised approach. These actions will be accomplished by December 31, 1980.
l10 J.
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Revision 10
. 23-35 11/80 e
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[
y7pw3gk UNITED STATES ATTACHMENT 15
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NUCt. EAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
\ 9
[
,m December 6,1979 Occket Nos. 50-329 50-330 1
Censumers Power Company ATTN: Mr. Stephen H. Howell Vice President 1945 West Parnall Road Jackson, MI 49201 Gentlemen: -
This letter transmits to you an 0,rder Modifying Construction Permits Nc.
CPPR-81 and No. CPPR-82. :This action is being taken as a result of fincings
, by inspectors from Region III, Office of Inspecticn and Enforcement made during the period of October 1978 to January 1979, and the conclusions of the NEC staff af ter reviewing responses to the 10 CFR 50.5c(f) request of March 21, 1979, regarding the proposed remedial work under and around safety-related structures and systems at the site, seme of which is c.irrently underway. Tne Order pertains to the problems associated with the soil foundation materials
,A at tne site.
k b
As part of the Order there are two Notices of Violation. The first Notice of Violation is Appendix A which contains information concerning four infractions with several examples, all of which relate to the soil foundation problems.
The second Notice of Violation, A pendix 3, contains infcmation concerning an item of n:necepliance which was determined to be a material false statement.
Actions that Consumers Power Company may take as a result of this Order are described in the Order.
Sincerely, Sincerely, h'-
g R_ ' A Ecson G. Case M
/ y/7* f:' "M Victor Stel'lo ,Wr.
Acting Director Director Of fice of Nuclear React:r Office of Inspection Regulation anc Enforcement
Enclosures:
- 1. Order Mccifying Construction ,
?ermits, CPPR-81 and CPPR-B2 l 2. A:pendix A
. 3. A pencix 3
/3 i i CERTIFIED FAIL
'd P.ITu;3 RECEIFT REOUES ED
)ofE 05 79/ 2.2.yooo y
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1 1
CIC 6 1373 ~
' Appendix 3 1
2-This information is false, in that materials other than controlled camcacted cohesive fill were used to support the diesel generator building and informa- i
' tion presented concerning the supporting soils influenced the staff review of
.the FSAR. -
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(
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
) - s CONSUMERS POVER COMPANY -
) Oceket No.'50-321.>
(Midland Nuclear Power Plant, ) 50~330 Units 1 and 2) . )
. ORDER MODIFYING CONSTRUCTION PERMITS I
The Consumers Power Company (the Licensee) is a holder of Construction Permits No. CPPR-81 and No. CPPR-82 which ;uthorize the construction of two pressurized water reactors in Midland, Michigan. The construction permits expire on October 1, 1981 and October 1, 1982, for Unit 2 and Unit 1 respectively.
II On August 22, 1978, the Licensee informed the NRC Resident Inspector at the l
l ['% Midland site that unusual settlement of the Diesel Generato Suilding had i
occurred. The Licensee reported the matter under 10 CFR 50.55(e) of the Co:re.ission's regulations by telephone on September 7,1978. This notification was followed by a series of interim reports dated September 29, 1978, November 7,1973, Dececber 21, 1978, January 5,1979, February 23,1979, April 3,1979, l
l June 25,1979, August 10, 1979, September 5,1979, and November 2,1979.
Following the September 1978 notification, inspectors from the Region III, Office of Inspection and Enforcement, conducted an investigation over the period of October 1978 through January 1979. This investigation revealed a breakdown in quality assurance related to soil construction activities under and around safety-related structures and systems in that (1) certain design
- and const uction specificatier.s related to foundation-type material properties O
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and compaction requirements were not followed; (2) there was a lack of clear j direction and ' support between the contractor's engineering office and construc-tion site as well as within the contractor's engineering office; (3) there was a lack of control and supervision of plant fill placement activities which contrit'uted to inadequate compaction of foundation material; (4) corrective action regarding noncomformances related to plant fill was insufficient or inadequate as evidence by repeated deviations from specification requirements; and (5) the FSAR con *ains inconsistent, incorrect, and unsupported statements with respect to foundation type, soil properties and ' settlement values. The details of these findings are described in the inspection reports 50-329/78-12, 50-330/78-12 (November 14, 1978) and 50-329/78-20, 50-330/78-20 (March 19, fQ 1979) which were sent to the Licensee on November 17, 1978 and March 22, 1979 O respectively.
[ The items of noncompliance resulting from the NRC investigation are described l
in Appendix A to this Order. In addition, as described in Appendix S to this Order, a material false statement was made in the FSAR in that the FSAR falsely stated that'"All fill and backfill were placed according to Ta le 2,5-9." Tnis statement is material in that this portion of the FSAR would have teen found unacceptable without further Staff analysis and questions if the Staff had l
I known that Category I structures had been placed in fact on random fill rather than controlled compacted cohesive fill as stated in the FSAR.
As a result of questions raised during the NRC investigation of the Diesel Generator Building settlement, additf ocal information was necessary to evaluate Gl l
.~_m.__.- - . . _ . __ - _ - . _ .-
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l 3-the impact on plant safety caused by soil conditions under and around safety-related structures and systems in and on plant fill, and the Licensee's related quality assurance program. On March 21, 1979, the Director, Office of Nuclear Reactor Regulation, formally requested under 10 CFR SG.54(f) of the ;
Commission's regulations information concerning these matters to determine wnether action'should be taken to modify, suspend or revoke the construction permit. Additional information was requested by the Staff in letters dated September 11, 1979 and November 19, 1979. The Licensee responded to these letters, under oath, in letters dated April 24,1979, May 31,1979, July 9, 1979, August 10, 1979, September 13, 1979, and November 13, 1979. The Licensee has not yet responded to the Novemoer 19, 1979 requests.
kp) v Several of the Staff's requests were directed to the determination and justification of acceptance criteria to be applied to various remedial measures taken and proposed by the licensee. Such criteria, coupled with the details of the remedial action, are necessary for the Staff to evaluate the technical -
adequacy and proper implementation of the proposed action. The information
- provided by ~the licensee fails to provide such criteria. Therefore, based on a review of the inferr.ation provided by the Licensee in response to the Staff questions, the Staff cannot conclude at this time that the safety issues l associated with remedial action taken or planned to be taken by the Licensee to correct the soil ceficiencies will be resolved. Without the resolution of tnese issues the Staff does not have reasonable assurance that the affected safety-related portions of the Midland facility will be constructed and l
/'"'
t operated without undue risk to the health and safety of,the puolic.
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III l
Under the Atomic Energy Act of 1954, as amended, and the Commission's l
regulations, activities authorized by construction permits or portions thereof' may be suspended should the Commission find information wnich would warrant the Commission to refuse to grant a construction permit on an original applica-ti o n.' We have concluded that' the quality assurance deficiencies involving the settlement of the Diesel Generator Building and soil activities at the Midland site, the false statement in the FSAR, and the unresolved safety issue concerning the adequacy of the remedial action to correct the deficiencies in the soil construction under and around safety-related structures and systems are adetuate bases to refuse to grant a construction permit and that, therefore, suspension
\]/
/
U
. of certain activities under Construction Permits No. CPPR-81 and No. CPPR-32 is warranted until the related safety issues are resolved.
IV Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the l Commission's regulations in 10 CFR Parts 2 and 50, IT 15 HEREBY ORDERED THAT, l
! subject to Part V of this Order, Construction Permits No. CPPR-31 and No.
CPPR-82 be modified as follows:
l l
l (1) Pending the submission of an amendment to the application seeking approval of the remedial actions associated with the soil activities for safety-related structures and systems founded in and on plant fill material and the issuance of an amendrent to Construction Permits No. CPPR-81 and
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- and No. CPPR-82 authorizing the remedial action, the following activities are prohibited:
~
(a) any placic), compacting, or excavating soil materials under or around safety related structures and systems; (b) physical implementation of remedial action for correction of soil related problems under and around these structures and systems, including but not limited to:
(i) dewatering systems p (ii) underpinning of service water building
- (iii) recoval and replacement of fill beneath the feedwater isolation valve pit area
. (iv) placing caissons at the ends of the auxiliary building electrical penetration areas
- (v) coccaction 'and leading activities; i
(c) construction work in soil materials under or around safety-related structures and systems such as fiele installation of concuits and piping.
(2) Paragraph (1) above shall not apoly to any exploring, samling, or testing
! of soil samples associated with cetermining actual soil properties en i
site whica nas tne a: proval of tne Dire: tor of Regici III, Office of
(
N Inspection and Enforcement.
-_ _ . , . . . _ . , _ . . . _ ._ . _ _ . . _ . . ~ , . ._. . _ , . . . . , _ . _ , _ . . _ . - _ . , _ , _ . _ .
l l
i f '-
.( 6-l V
The Licensee or any person yhose interest is affected by this Order may within 20 days of the date of this Order request a hearing with respect to all or any p' art of this Order. In the event a hearing is requested, the issues to be considered will be:
(1) whether the facts set forth in Part II of this Order are correct; and
'(2) whether. this Order should be sustained.
l.p This Order will become effective on the expiration of the period during which
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.a hearing may be requested, or in the event a hearing is requested, on the date specified in an Order made following the hearing.
FOR THE NUCLEAR REGULATORY COMMISSION
&- '~ /jsk R $
- cson G. Case, Agting Director Victor 5tel ha, Jrg Director 46fficeofHuclearReactor Office of Inspect' ion Regulation and Enforcement i
Attacht::ents:
- 1. Acpencix A
- 2. A;pendix 3 l .0ated at Bethesda, Maryland, tais lo # - day of Cece:ter, 1979.
l
DEC 6 1579 ,
n I
! Aeoendix A l
, \
l NOTICE OF VIOLATION
- 1 l
. Consumers Power Company - Oceket No. 50-329
, Oceket No. 50-330 This refers to the finvestigation conducted by the Office of Inspection -
'and Enforcement at the Midland Nuclear Power Plant, Units 1 and 2 Midland, Michigan, at your offices in Jackson, Michigan, 'and at Bechtel Corporation, Ann Arbor, Michigan -of activities authorized by NRC License No. CPPR-81 and No. CPPR-82.
Based on the results of the investigation conducted during the period '
Oncember 11, 1978 through January 25, 1979, it' appears that certain of your activities were not conducted in full compliance with NRC require-
, ments as noted below. These items are infractions.
- 1. 10 CFR 50, Appendix B, Criterion III requires, in part, that measures shall be established and' executed to assure that regulatory requirements and.the design basis as specified in the license application for-structures are correctly translated into specifications, drawings, '
procedures and instructions. Also, it provides that measures shall 1 be established for the identification and control of design inter-faces"and for coordir,ation among participating design organizations.
-D '
CPCo Topical Report CPC-1-A, Policy No. 3, Section 3.4 states, in part, '?tne assigned lead design group or organization (i.e. , the NSSS supplier, A&E supplier, or CPCo) assure that designs and l materials are suitable and that they comply with design criteria and
[ regulatory requirements."
i' CPCo is committed to ANSI N45.2 (1971), Section 4.1, which states, in part, " measures shall be established and documented to assure that the appitcable specified design requirements, such as a design basis, regulatory' requirements . . . are correctly translated into specifications, drawings, procedures, or instructions."
Contrary to the above, measures did not assure that design bases were included in' drawings and specifications nor did they crevide for the identification and control of design' interfaces. As a result, inconsistencies were . identified in the license acplication and in other design basis documents. Specific examples are set forth below:
- a. The FSAR is internally inconsistent in that FSAR Figure 2.5-45 indicates settlement of the Diesel Generator Building to be on the orcer of 3" wnile FSAR Section 3.3.5.5 (structural accept-ance criteria) indicates settlements on shallow spread footings W6 0F yp70009
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Appendix A v founded on compacted fill to be on the order of 1/2" or less.
The Diesel Generator Suilding is supported by a continuous shallow spread footing,
- b. The design settlement calculations for the diesel generator and borated water storage tanks were performed on the assumption of uniform mat foundations while these foundations were desigr.ed and constructed as spread footing foundations,
- c. The settlement calculations for the Diesel Generator Building indicated a load intensity of 3000 PSF while the FSAR, Figure 2.5-47, shows a load intensity of 4000 PSF, as actually constructed.
- d. The settlement calculations for the Diesel Generator Building were based on an index of compressibility of the plant fill bet een elevations 603 and 634 of 0.001. These settlement values were shown in FSAR Figure 2.5-48. However, FSAR, Table 2.5-16, indicates an index of ceopressibility of the same plant fill to be 0.003.
- e. PSAR, Amendment 3, indicated that if filling and cackffiling
! cperations are discontinued during periods of cold weather, all i /n\ frozen soil would be removed or recompacted prior to the resump-l C tion of operations. Bechtel specification C-210 does not specif-ically include instructions for removal of frozen / thawed compacted material upon resumption of work after winter periods.
- f. PSAR Amendment 3 indicates that cohesionless soil (sand) would be compacted to 85% relative density according to ASTM 0-2049.
However, Bechtel specification C-210, Section 13.7.2 required cohesionless soil to be compacted to not less than 80% relative density.
- 2. 10 CFR 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribed and accomplished in accordance with documented instructions, procedures or drawings.
CPCo Topical Report CPC-1-A, Policy No. 5, Section 1.0 states, in part, that,
- Instructions for controlling and perfor ing activities affecting quality of equipment or operation during design, construc-i tion and cuerations phase of the nuclear power plant such as procure-ment manufacturing, construction, installation, inspectien, testing
. . are doo'.mented in instructions, procedures, specifications . .
. these sce:ents provide cua'itative and cuanititive acceptance criteria for determining important activities have oeen satisfactorily ac co:pl i shed. "
O t i v
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l l
l CEC 6 GM o( ) Appendix A ' l l
l CPCo is comited to ANSI N45.2 (1971), Section 6 which states, in part, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
- a. Contrary to the above, instructions provided to field construc-tion for substituting lear, concrete for Zone 2 material did not
. address the differing foundation properties which would result in differential settlement of the Diesel Generator Building.
- b. Also, contrary to the above, certain activities were not accom-plished according to instructions and procedures, in that:
(1) The compaction criteria used for fill material was 20,000 f t-lbs (Bechtel modified proctor test) rather than a coepactive energy of 56,000 ft-lbs as specified in Bechtel Specification C-210, Section 13.7.
(2) Soils activities were not accomplished under the continuous supervision of a qualified soils engineer who would perform in place density tests in the compacted fill to verify tnat all materials are placed and compacted in accordance with specification driteria. This is required by Bechtel n\
, (h l Specification C-501 as well as PSAR, Amendment 3 (Dames and Moore Report, page 16).
- 3. 10 CFR 50, . Appendix 8, Criterion X requires, in part, that a program for inspection of activities affecting quality shall be established
.and executed to verify conformance with tne documented instructions, procedures and drawings for acccmplishing the activity.
L CPCo Topical Report CPC 1-A, Policy No. 10, Section 3.1, states, in part, that " work activities are accomplished according to approved precedures or instructions which include insoection hold points beyond which work does not proceed until the inspection is complete or written consent for bypassing the inspection has been received from the organi:ation authorized to perform the inspections."
CCCo is c ecited to ANSI N45.2 (1971),- whien states, in part, "A program for inspection of activities affectirg cuality snall be estaolisnec and executed by or for the organi:ation performing ne activity to verify confomance to the documented instructions, procedures, and crawings for ace:mplishing the activity."
Contrary to the above, Quality Control Instruction C-1.02, the pre; ram for inspec fon of c:moac ed :ackfill issued on Oct:ber 13, 1975, did not provice for inspectirn hold points to verify that soil work was satisf act:rily accomplisned ace:rdi ,g t: documented instructions.
'% s
. . l CIC 6 i35 A .
. Appendix A 4. 10 CFR 50, Acpendix 3, Criterion XVI requires, in part, that mea-sures shall be established to assure that conditions adverse to
. quality such as failures, deficiencies, defective material and nonconformances are promptly identified and corrected. In case of significant conditions adverse to quality, measures'shall assure that corrective action is taken to preclude repetition.
CPCo Topical Report CPC-1-A, Policy No. 16, Section 1.0 states, in part, " corrective action is that action taken to correct and pre-
, clude recurrence of significant conditions adverse to the quality of items or operations. Corrective action includes an evaluation of the conditions that led to a nonconformance, the disposition of the nonconformance and completion of the actions necessary to prevent or
. reduce the possibility of recurrence."
Contrary to the above, measures did not assure that soils conditions of adverse quality were promptly corrected to preclude repetition.
For example:
- a. As of January 25, 1979, moisture control in fill material had not been established nor adequate direction given to implement this specification requirement. The finding that the field was
!p not performing moisture control tests as r2 quired by specifi-l t cation C-210 was identified in Quality Action Request 50-40, l \ dated July 22, 1977.
- b. Corrective action regarding nonconformance reports related to plant fill was insufficient or inadequate to preclude repeti-tion a5 evidenced by repeated deviations from specification requirements. For example, nonconformance' reports No. CPCo QF-29, QF-52, QF-68, QF-147, QF-174, QF-172 and QF-199 contain i numberous examples of repeated nonconformances in the same areas of plant fill construction. i l
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