ML20126L838

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Testimony of Jd Kane That Inadequate Compaction & Failure to Attain Min Compaction Criteria Designated Are Major Reasons for Facility Settlement Problem.Prof Qualifications Encl
ML20126L838
Person / Time
Site: Midland
Issue date: 06/08/1981
From: Kane J
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20126L803 List:
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8106090676
Download: ML20126L838 (8)
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V UNITED STATES OF AfiERICA NUCLEAR REGULATORY COMf11SS10fl BEFORE THE AT0f11C SAFETY AND LICENSING BOARD In the Matter of ) ,

C0flSUMERS- POWER C0f1PANY Docket Nos. 50-329 OM & OL

). 50-330 01 & OL (liidland Plant, Units' 1:and 2) -)

TESTIMONY OF-JOSEPH D. KANE WITH RESPECT TO THE QUALITY QUALITY ASSURANCE PROGRAM IMPLEMENTATION PRIOR TO DECEMBER 6, 1979 Q.1. Please state your name and position with the NRC.

A.  !!y name is Joseph D. Kane. fiy position with the U.S. Nuclear Re]ulatory Commission is Principal Geotechnical Engineer and I an

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assigned to the Geotechnical Engineering Section of the Hydrologic -

and Geotechnical Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation.

-Q.2. Have you prepared a statement of professional qualifications?

A. Yes. A copy of this statement is attached.

Q.3. Please state-the nature of the responsibilities that you have had with respect to the itidland Plant, Units 1 & 2.

A. fly review involvement with the flidland project essentially began in November 1979 when I was assigned the responsibility of serving as technical monitor for the interagency contract between the f4RC and the U.S. Army Corps of Engineers, Detroit District (hereafter the Corps). The purpose of this interagency contract was to obtain the

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V) i service of expert technical personnel from the Corps to assist the

  • f1RC in the safety review of the liidland project in the field of geotechnical engineering. fly responsibilities as contract technical monitor include assisting the Corps in their reviert efforts, examining and commenting on their evaluation reports and coordinating the Corps review efforts with other f4RC Branches in technical areas of overlapping safety concern. In addition I have assisted in preparation of interrogatories and responses to interrogatories with regards to the soil settlement problem at the Midland plant. Since llovenber 1979 my involvenent in the review of the liidland project has steadily increased to the point that it is now the major portion of my work at f1RC. In addition to responding (m to Consumers appeal actions (e.g., the appeal of the June 30, 1980 .

% request .for additional borings and laboratory testing) and participation in discovery deposition proceedings, I an extensively involved in the assessment of the adequacy of the renedial measures proposed by Consumers. These remedial fixes are necessary to address the nany problens caused by the unanticipated settlenent of safety related* structures and piping due to the inproperly compacted plant fill.

l Q.4. Please state the purpose of this testimony.

l1 A. .The purpose of this testimony is to supplement the testimony prepared by Eugene J. Gallagher. In response to question 32, Mr.

1 Gallagher' stated that quality assurance deficiencies resulted in the plant im l

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fill being insufficiently compacted. Mytestimonydemon'stratesithat if the original compaction control requirements set forth in the PSAR had been followed, the plant fill settlement problem would not have occurred.

i Q.5. What.is the basis for your response to Question 4?

A. As indicated in Mr. Gallagher's testimony in response to Question 22, the NRC at the PSAR licensing stage considered the designated mininum compaction criteria and recommended moisture content

. placenent control .to.be design and construction commitments by CPC'.

(The compaction criteria and moisture control requirement at the PSAR stage are summarized in Table 2.5.4, sheet 3 of the FSAR in response to NRC question 362.15). The significance of these -

commitments is extremely important to the expected performance of

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the plant fill. The engineering profession widely recognizes the importance of adequate controls on compaction and noisture content for soils which are intended to satisfactorily support structures.

This wide recognition comes about tecause of the acknowledged relationship between the state of a soil's compactness and the soil's accepted behavior as an engineering material. CPC, when they indicated that soils which were to support structures would be compacted to a stated percentage of a laboratory established maximun density at a moisture content near optimun, were, in effect, convincing the NRC Staff at the CP Stage that engineering properties of compressibility and shear strength would be acceptable. What has

, W been experienced at Midland (i.e., the plant fill significantly l .

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, u settling under its own weight; foundation supporting safety related structures having very low penetration resistance to spoon samplers; and extensive cracking of structures founded on compacted fill) proves that soils were not' compacted to the designated mininun compaction criteria established at the PSAR stage.

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Q.6. Do other engineers share your conclusion that the cause of the plant fill settlement problen resulted from inadequate compaction or construction of an unsatisfactory plant fill?

A. Yes. Engineers- from both the Corps and the NRC staff have the opinion that inadequate compaction and failure to attain the mininun compaction criteria designated at the PSAR stage are the najor reasons for the _ settlement problen at liidland. .In addition, in ny

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opinion, statenents obtained in the discovery depositions from Bechtel and their consultants support this conclusion. The following is from lines 7-10 at page 97 of the deposition of Sherif -

Afifi (Bechtel employee) taken on October 29, 1980; BY I4R. PAT 0th Q. Doctor, do you have any opinion as to what caused the extensive settlement problen in the plant fill at liidland?

A. Inadequate compaction.

The following is from lines 18-25 at page 15 and lines 1-3 at page 16 of the deoosition of Dr. Ralph B. Peck (Bechtel consultant) taken on January 13, 1981; Q. All right. What is your opinion of. the quality of the soils placement that had taken place prior to your being hired on the tiidland project?  ;

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1 O MR. FARf1 ELL: Are you talking about the whole power plant? Or are you talking about specific parts of it?

MR. J0NES: The soils portions of the project with which he was closely associated.

A. My opinion, or perhaps you could say it was ny conclusion was that the fill' beneath the diesel generator building area and sone neighboring areas was not a satisfactory fill.

'The following is from lines 5-16 at page 41 of the deposition of Or.

Alfred J. Hendron (Bechtel consultant) taken on January 27, 1981; Q. With respect to your construction of the fill do you have any opinion as to the quality of that work?

Were you going to speak?

NS. BLOOM: Yes, I was going to -- I think we have outlined what. kind of work we are talking about here.

MR. JONES: Construction of fill?

O i THE 141TNESS: I think when a fill is settle two to four inches under its own weight, and some places have a very low slow

[ sic]_ count which obviously something went wrong and I cannot say whose fault or what it might have been, but, there were some bad fills there, not as good as it should have been. I shouldn't say had fills, there is a difference.

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Attachment 1

'O PROFESSIONAL QUALIFICATIONS AND EXPERIENCE NAME: Joseph D. Kane ADDRESS: 7421 Miller Fall Road Derwood, MD 20855 EDUCATION: B.S. Civil Engineering 1961 Villanova University M.S. Civil Engineering 1973 Villanova University Post-degree studies, Soils and Foundation Engineering University of California 1972 University of Maryland 1978 PROFESSIONAL REGISTRATION:

Registered Professional Engineer (1966) - Pennsylvania 12032E PROFESSIONAL SOCIETY:

American Society of Civil Engineers EMPLOYMENT POSITIONS:

February 1980 - Present Principal Geotechnical Engineer U.S. Nuclear Regulatory Comission May 1977.- February 1980 Geotechnical Engineer U.S. Nuclear Regulatory Commission October 1975 - May 1977 Soils Engineer U.S. Nuclear Regulatory Comission August 1973 - October 1975 Supervisory Civil Engineer Chief, Soils Design Section l

U.S. Army Corps of Engineers l

Philadelphia District l

January 1963 - August 1973 Civil Engineer Soils Design Section U.S. Army Corps of Engineers Philadelphia District l

January 1962 - January 1963 Design Engineer McCormick - Taylor Associates Philadelphia, Pa.

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Professional Qualifications [N and Experience Joseph D. Kane PROFESSIONAL EXPERIENCE

SUMMARY

1975 to Present In itRC Division of Engineering, Geotechnical Engineering Section, Mr. Kane has specialized in soil mechanics and foundation engineering. Experiences in this position have included the following:

e. Evaluation of the foundation adequacy of proposed sites for nuclear facilities with respect to design and operational safety. This work has included evaluation of geotechnical, soils and rock mechanics, foundation and earthquake engineering related aspects.

The results of this review effort are summarized in a safety evaluation report for each of the proposed facilities which have included nuclear power plants, nuclear fuel reprocessing plants and uranium mill tailings waste systems,

b. Serving as a technical adviser for soil and foundation engineering related aspects in the development of regulatory guides, acceptance and performance criteria

, that are intended to assure construction and -

(Qj operational safety of nuclear facilities.

c. Serving as a technical representative for the Office of Nuclear Reactor Regulation on the flRC Advisory Group concerned with federal dam safety.
d. Serving as an instructor for the Office of State ,

Programs in tha training nf state personnel who are responsible for constructica and operational inspections of uranium mill tailings embankment retention systems.

1963 tc 1975 During this period Mr. Kane was employed with the U.S.

Army Corps of Engineers, Philadelphia District and attained the position, Chief, Soils Design Section, Foundations and Materials Branch, in 1973. Professional experiences with the Corps of Engineers have includad the following:

a. The embankment and foundation design of four large multi-purpose earth and rockfill dams with appurtenant structures (spillways, inlet and outlet structures, control towers, flood protection facilities, etc.).

Responsibilities ranged from the initial planning of fx

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t L- fsg Professional Qualifications- l

( ) and Experience I v Joseph D. Kane 1 1

subsurface investigations to select the most feasible sites through all design stages which were culminated in the final preparation of.

construction plans and specifications. This work included planning and evaluation of laboratory testing programs, studies on slope stability, seepage control and dewatering systems, settlement, bearing capacity, liquefaction, embankment safety instrumentation and slope protection.

b. Served as a technical consultant to field offices charged with construction inspections for assuring completion of structures in compliance with design analysis and contract specifications. Participated in the development of needed modifications during '

construction whenever significant changed site conditions were uncovered.

c. Directed the efforts of engineers in the Soils Design Section in other fields of civil work projects that

~~s included the embankment and foundation design of ,

I I levees, waterfront pile supported structures and

\s. # disposal basins for the retention of hydraulic dredge waste.

1962 to 1963 Served as design and project engineer for orivate consulting firm. This work included the design of large federally funded highways, a race track and various structures constructed to provide a Pennsylvania State park marina.

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