ML20126L854
| ML20126L854 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/08/1981 |
| From: | Gallagher E, Hood D, Kimball J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20126L803 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8106090695 | |
| Download: ML20126L854 (46) | |
Text
' 7 ff l UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l In the Matter of )
)
CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OM & OL
) 50-330 OM & OL l (Midland Plant, Units 1 and 2 )
NRC STAFF TESTIMONY OF DARL S. HOOD, JEFFREY K. KIMBALL AND EUGENE GALLAGHER ON STN<tIRIS CONTENTION 1 Q . 1. Please state your names and positions with the NRC.
A. My name is Darl S. Hood. I am a Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
My name is Jeffrey K. Kimball . I am a Seismologist /Geophysi-cist reviewer within the Geosciences Branch, Division of Engineering, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission.
My name is Eugene J. Gallagher. I am a civil engineer with the U.S. Nuclear Regulatory Commission. Since February,1981, I have been assigned to the Reactor Engineering Branch, Division of Rasident and Regional Reactor Inspection, l Office of Inspection and Enforcement. Prior to February,1981, I was a reactor inspector assigned to the Region III, Reactor Construction and Engineering Support Branch, Office of Inspection and Enforcement.
Q. 2. Have you prepared statements of professional qualifications?
A. Yes. Copies of these statements are Attachment 1.
8106090 N
y .g
)
2-Q. 3. Please state the duration and nature of your responsibilities with respect to the Midland Plant, Units 1 and 2. j A. I, Darl Hood, am the Project Manager for the Midland Plant application f for operating licenses. I have served in that position from August 29, 1977, when the application for operating licenses was tendered to the NRC for acceptance review, up to the present time. My responsibilities include management of the Staff's environmental and radiological safety revie.;. I am responsible for the Staff testimony on the following parts of Stamiris' Contention 1: (a);
Supplemental Items 2, 3, 4 and 6; and portions of Supplemental Items 1 and 5.
I, Jeffrey Kimball, have served in the position of Seismologist /
Geophysicist reviewer for the Midland Plant since July 1980. I am responsible for j the Staff testimony on part 1 (b) of Stamiris Contention 1.
I, Eugene Gallagher, was assigned to the Midland Plant (among others) from October,1978 until January,1981. Since October of 1978, I have spent approximately one year of effort performing inspections, reviewing quality control records and procedures, observing work activities, reviewing Consumers ;
Power Company (hereafter CPC or Applicant) responses to 10 CFR 50.54(f) questions 1 and 23, and attending meetings and presentations by CPC and Bechtel regarding the soil settlement matter at the Midland Plant. I am responsible for the Staff testimony for portions of Supplemental Items 1 and 5 to Stamiris' Contention 1.
i Q. 4. Please state the purpose of this testimony.
A. The purpose of this testimony is to address Contention 1 of the Contentions of Barbara Stamiris as identified in the Appendix to Prehearing Conference ew % *,9-+y y *_m y -
m ,g,,--w- r--
-(. :(
Order Ruling on Contentions and on Consolidation of Proceedings, dated October 24, 1980, and as supplemented by Intervenor Answer To Applicant's Interrogatories, dated April 20,1981. This testimony does not address Stamiris Contention 1 (d) since this relates to matters to be addressed at a later time.
Stamiris' Contention 1 reads as follows:
Consumers Power Company statements and responses to NRC regarding soil settlement issues reflect a less than complete and candid dedication to providing information relevant to health and safety standards wit.h respect to resolving the soil settlement problems, as seen in:
a) the material false statement in the FSAR (Order of Modification, Appendix B);
b) the failure to provide information resolving geologic classification of the site which is pertinent to the seismic design input on soil settleinent issues (Responses to FSAR Questions 361.4, 361.5, 361,7 and 362.9);
d) the failure to provide adequate acceptance criteria -
for remedial actions in response to 10 CFR $50.54(f) requests (as set forth in part II of the Order of Modification);
and this managerial attitude necessitates stricter than usual regulatory supervision ( ALAB-106) to assure appropriate implementation of the remedial steps required by the Order Modifying Construction Permits, dated December 6,1979.
April 20,1981 Supplement to Contention 1 Examples of CPCo. reluctance to provide requested information
- 1. 3/31/80 NRC meeting notation of Applicant's reluctance to provide NRC consultants with requested information.
- 2. Vol . III, tab 65 50-54f, 8/6/79 meeting, attitude that
" needlessly conservative decisions may be formulated on the 'what if' type questions" by the NRC on dewatering.
- 3. The 11/24/80 S. A.L.P. assessment on CPCo - NRR interface as presented by D. Hood in the following statements regarding soil settlement issues:
i l
1
- , ~ , - - - . . . , - .,_,.,m . . , - , , - , - - , _ - , . . , . . . , - - , . . - . _ . ., , - _ - . -- , . - . - -
i 1 1
"A big contributor to the inability to make meaningful progress in this matter is the quality of responses gotten. We have set some kind of record on the number of questions re-asked, which speaks poorly for CPCo-NRR interface. ...The bottomline is there seems to be a lack of appreciation or support of Staff review necessities and a tendency to push ahead despite the lack of proper assurances."
- 4. The perfunctory manner in which CPCo. deponents answered questions. (I will tabulate examples from the depositions I attended.)
Examples of information withheld or incorrectly given:
- 5. The failure of CPCo. to discuss the Administration Building settlement problem with the NRC, as they did with their consultants, in the early meetings on the DGB settlement.
- 6. The false FSAR statements beyond the one cited as a
" material false statement" in the Dec. 6 Order, as discussed in the 4/3/79 Keppler-Thornburg memo, and the 6/13/79 Thornburg - Thompson memo.
Q. 5. What is the NRC Staff response to Contention 1(a)? '
A. Information submitted as part of an application for licenses in accordance with 10 CFR 50.30 is " material" if that information should or could have an influence upon a safety conclusion of the NRR Staff. A material statement which is' false is of cortcern if it could have resulted in an improper finding or a less probing analysis by the NRR Staff.
The material false statement referred to in Contention 1(a) is described in Appendix B to the Order Modifying Construction Permits, dated December 6, 1979. Specifically, the material false statement was made in Section 2.5.4.5.3 of the FSAR. That section provided that "all fill and backfill were placed according to Table 2.5-9". Had the Staff relied on this statement, it would or could have erroneously concluded that the fill and
( ~1 backfill placed for the support of structures and the Diesel Generator Building i consisted of " clay" (Table 2.5-9 under " Soil Types") or " controlled compacted cohesive fill" (Table 2.5-14 under " Supporting Soils") which had been compacted, as a minimum, to 95% of ASTM D 1557-66 T modified to get 20,000 foot-pounds of compactive energy per cubic foot of soil (see Table 2.5-9 under " Compaction Criteria"). The reality of the situation is that the fill and backfill beneath the structures and the Diesel Generator Building are neither " clay" nor a " controlled compacted cohesive fill", but consist of a heterogeneous mixture of sand, clay, silt and lean concrete, and the minimum compaction criterion implied as having been achieved by the quoted statement from FSAR Section 2.5.4.5.3 was not achieved.
Therefore, a conclusion by the Staff that the fills and backfills -
were of a different type or had been compacted to known minimum standards would have been eroneous and would or could have precluded a more probing analysis or further questioning. Based upon the FSAR information, the Staff would or could have concluded that the structure was adequately supported, that it would not experience detrimental settlement, that its foundations would remain stable under both static and earthquake loading, and that the fill properties would be at least equal to design values provided in the FSAR. The Staff's conclusion would have been relevant to the NRC findings pursuant to 10 CFR 50.57 (3) for issuance of operating licenses and would have contributed to a finding that there is reasonable assurance that the activities authorized by the cperating license can be conducted without endangering the health and safety of the public.
l
I i 1 1 i i
l i
i I
I I do not agree with Contenti6n 1(a) to tha extent that the material l 1
false statement is a reflection of "a less than complete and candid l dedication to providing information relevant to health and safety standards l with respect to resolving the soil settlement problems." In my opinion the material false statement in the FSAR is a reflection of the breakdown in quality assurance and quality control that existed for the flidland plant prior to December 6,1979 for requirements such as design control (Criterion III of 10 CFR Part 50, Appendix B) and document control (Criterion VI of 10 CFR Part 50, Appendix B). I have no reason to believs, nor do I believe, that this material false statement was intentional. !
k Similarly, I have heard no one else express this view that the was intentional. I Q. 6. What is the HRC Staff response to Contention 1(b)?
)
A. FSAR Questions 361.4, 361.5 and 361.7 referred to in Contention 1(b) were asked by the NRC's Geosciences Branch as part of its review of the Midland Plant application for operating licenses. Question 361.4 was issued on June 20, 1978; the Applicant's latest response prior to issuance of the December <
6,1979 Order on Modification was by FSAR Revision 15 (Amendment 54) dated Novemt.er l
27,1978, (Attachment 2) and the current response was by FSAR Revision 30 ( Amendment i
- 83) dated October 21,1980 ( Attachment 3). Question 361.5 was also issued on June 20, 1978; the Applicant's latest response prior to December 6,1979 was by FSAR Revision 14 ( Amendment 51) dated October 17,1978 ( Attachment 4),
and the current response was by FSAR Revision 30 ( Amendment 83) dated October 21, 1980 ( Attachment 5). Question 361.7 was issued on February 14, 1979; the Applicant k
.I t-responded' by FSAR Revision 24 (Amendment 69) dated September 28, 1979
( Attachment 6)..
e Question 362.9 was asked by the NRC's Geotechrical Engineering section on' August 30, 1978; the Applicant's latest response prior to December 6,1979 was by FSAR Revision 24 ( Anendment 69) dated September 28,1979 ( Attachment 7) and the
' current response is by FSAR Revision 26 (Amendment 73) dated J nuary 30, 1980 ;
( Attachment 8).
The Applicant'did not fail to provide information in responding to Questions 40. 4, 361.5 and 361.7 as alleged in Contention 1(b); however, the inf'ormation contained in the responses to these three questions did not resolve !
.the open issue involving which tectonic province the Midland site is in. *
~
Specifically, the Applicant had used the Michigan Basin tectonic province whereas the NRC staff. has been reluctant to accept subdivision of the whole Central Stable Region tectonic province.
Question 362.9 inquired about structural settlement measurements from certain. benchmark numbers. The relationship, if any, of this subject to information resolving geologic classification of the site as alleged in Contention 1(b) is not understood, and Question 362.9 was not asked for such a purpose.
The Staff does not view the tectonic province disagreement between itself and CPC as any reflection of "a less than complete and candid dedication" to providing information relevent to resolving the open issue which is necessary for approval of the remedial actions associated with the soil settlement matter.
I
...-u._..- - . . , _. - _ , . _ . . . . _ . _ , _ _ . . . _ _ . . _ _ . _ - - , . , . - - . -
f 1 l
l l
l Q. 7. What is the NRC Staff response to Item 1 in Stamiris' supplement to Contention l?
A. Item I refers to a March 31,1980 " meeting notation".
This is a reference to the " Summary of February 27 & 28, 1980 Meeting and Site Tour with Consultants to Review Soil Settlement" ( Attachment 9). The statement of interest is the first paragraph on page 3 of this meeting summary:
The staff noted that such documents as above are needed by its consultants for their independent assessment of the adequacy of the proposed remedial measures and requested that these be made publicly available. The applicant indicated a reluctance to this end, and noted that these were available through the I&E audit mechanism.
The . staff will issue a formal request for these documents.
The above statement refers to a discussion by the Applicant during the meeting in response to our request for documents. The Applicant -
replied, as best I can recali, that many of these documents are of a type not normally found within the docketed material of an application for licenses, and that the documents requested would be quite volumnious. The purpose of the comment, I believe, was to explore the possibility that the Staff's need for the documents might be accomplished through a less burdensome and expensive mechanism, such as the audit mechanism which would provide for NRC review at a local record center such as Bechtel, in Ann Arbor, Michigan.
The Staff, in fact, formally requested the documents by letter dated April 1,1980 ( Attachment 10). The Applicant replied initially by coverletter dated May 5,1980 forwarding Amendment 77 and copies of Revision 7 to the document
2
- f. -1 l
l 1
ontitled " Responses to NRC Requests Regarding Plant Fill." This coverletter acknowledged that five of the requested reports were not being forwarded at that time; two of the five had been superseded and the two replacement documents, also named in the staff request, would be forwarded as they became available. These four reports discuss the Sondex system and Borros Anchor procedures.
The fif th document identified for submittal at a later time ,
in the Applicant's May 5,1980 coverletter discussed qualification of compaction equipment. The documentation for qualification of compaction equipment had been previously requested by the Office of Inspection and Enforcement (IE) on December 4, 1978 as described by "Sumary of December 4,1978 meeting on Structural Settlements" ( Attachment 11), page 4, which states in part:
The NRC Resident Inspector asked for a list of the equipment, with a discussion of the d.,mpaction capability and limitations of each, used for compacting the fill for the DG Building from elevation 618 to 628 feet. Bechtel will provide this information.
This documentation was again requested unsuccessfully during IE site visits around mid 1979 and in May 1980 (Attachment 12). The Applicant's reply of August
(
l 15, 1980 forwarded, in part, a report on the Test Fill Program (tab 150 in " Responses i
to NRC Requests Regarding Plant Fill") which was conducted between May 1979 and October 1979 to requalify various compactors for structural and pit run sands.
The August 15, 1980 reply also noted that "further testing is being conducted in f order to substantiate qualification of certain equipment."
i I
1 1
1 l
l i
I t While the difficulty and delay associated with acquiring documentation with respect to qualification of soils compaction equipment represents an instance of poor cooperation with NRC, the Staff does not believe that the discussions during the meetings of February 27 and 28,1980, nor the subsequent actions of the Applicant to comply with the Staff request for documents other than those documents on qualification of soils compaction equipment, reflect an overall a deficiency in atti tude. However, this poor cooperation reflected adversely upon the responsible officials involved in execution of CPC's quality assurance program.
Q. 8. What is the NRC Staff response to Item 2 in Stamiris' supplement to Contention 1?
A. The statement referreo to in Item 2 is found in tab 66 of the document " Responses to NRC Requests Regarding Plant Fill". It specifically appears in the last paragraph of an internal correspondence by T. C. Cooke/RMW (R.M. Wheeler) which was prepared either on August 6 or 7,1979 to summarize a pre-meeting of June 27, 1979 between CPC, Bechtel and Bechtel's consultants (Attachment 13).
The neeting sunnary is somewhat ambiguous as to the source of this j statement. The entire last paragraph of the meeting summary, including this statement, appears to indicate the views of the consultants. Froni my reading of this paragraph, I believe the intent is to reflect the expressions of the consultants.
4 l ,
I am unable to conciede that the cited example reflects the view of-any member of CPC. Views expressed by Bechtel's consultants ,
on their own behalf, as may possibly be the case here, would not be a reflection on the Applicant's dedication to providing information nor if.e Applicant's managerial attitude. Furthermore, this cited example has nothing to-do with CPC's alleged reluctance to provide requested information. Similarly, the statement does not demonstrate one way or the other whether CPC has a "less than complete and candid dedication to providing information."
Q. 9. What is the NRC Staff response to Item 3 in Stamiris' supplement to Contention 17 A. Item 3 refers to the SALP assessment of CPC. SALP, or Systematic Assessment of Licensee Performance, is an NRC program for the comprehensive overview of licensee or applicant performance. The program was included as Task I.B.2 in the " Action Plans for Implementing Recommendations of the President's Commission and Other Studies of TMI-2 Accident", HUREG-0660. The program is also discussed in House Report No. 96-1452, by the Committee on Government Operations, entitled, " Evaluating Nuclear Utilities Performance: Nuclear Regulatory Commission Oversi ght. " The objectives of SALP are:
(1) Identification of unacceptable licensee performance; (2) Improvement of licensee performance; )
(3) Improvement of IE Inspe: tion Program; I l
l j
4 .t (4) Providing a basis for NRC management's allocation of resources; and (5) Achieving regional consistency by appraising licensee performance from a national perspective.
Further description of SALP is provided in SECY 80-83 ( Attachment 14).
Performance reviews and evaluations for SALP are conducted semiannually by a board consisting of NRC individuals who are involved in the inspection and licensing activities of the applicant or licensee such as resident inspectors, regional inspectors, regional managers, and NRR Project Managers. As Project Manager for the Midland plant, I, Darl Hood, am a member of the SALP Board responsible for'the review and evaluation of the Midland Plant, Units 1 and 2. I pa,-ticipated in a meeting on November 24, 1980 between the SALP Board and CPC which was held to advise CPC of the results of the SALP evaluation for its nuclear plants, including Midland Plant, Units 1 and 2. During this meeting -
I made the statement:
A big contributor to the inability to make meaningful progress in this matter is the quality of responses gotten. We have set some kind of record on the numoer of questions re-asked, which speaks poorly for CPCo - NRR interface. ...The bottomline is there seems to be a lack of appreciation or support of Staff review necessities and a tendency to push ahead despite the lack of proper assurance.
Two examples that I had in mind when I made the above bottomline statement were associated with the Applicant's decision (1) to place and remove the surcharge for the Diesel Generator Building without first providing an adequate response to 50.54(f) Request 4, and (2) to proceed with construction of the Borated Water Storage Tanks without first performing the analyses for variable foundation properties and cracks as discussed in the response to 50.54(f) Request l 14.
1
4 L4 The statement cited above notes my agreement with Ms. Stamiris' contention that CPC has exhibited a reluctance to provide requested information.
Q . 10. What is the NRC Staff response to Item 4 in Stamiris' supplement to Contention l?
l A. Without the tabulated examples of "the perfunctory manner in which CPCo deponents answered questions" promised by Ms. Stamiris in her j 1
contention, the Staff is unable to evaluate or address this contention.
i Q. 11. What is the NRC Staff response to Item 5 in Stamiris' supplement l to Contention I?
A. This contention lists an example which claims to represent information )
{
withheld by the Applicant from the NRC. The specific example cited is, "The . j l
failure of CPCo. to discuss the Administration Building settlement problem with the NRC, as they [ CPCo ] did with their consultants, in the early meetings on the DGB settlement."
l Ms. Stamiris is correct in her statement that CPC did not i 1
discuss the settlement of the Administration Building grade beam with the NRC during early meetings on the Diesel Generator Building settlement or associated site visits of late 1978. Although the Administration Building is not a safety l related structure and CPC was not bound by 10 CFR 50.55(e) to report such l- a problem, the existance of that earlier problem was clearly of I
l relevance to the 50.55(e) reports and reviews regarding Diesel Generator l
l Building settlement.
4 4 t
The NRC first learned of the Administration Building grade beam
. problem during the NRC investigation into the Diesel Generator Building settlement while at Bechtel's Ann Arbor office in January 1979. At that time, the Bechtel civil design supervisor, Mr. G. Tuveson, informed the NRC of a similiar problem with the Administration Building and provided the NRC with a December 1977 report on the issue.
The NRC documented this information in pages 21-23 of NRC investigation report 78-20 (see Attachment 2 of Staff Testimony on Stamiris' Contention 3), which describes various simularities between the Administration Building settlement and the Diesel Generator ' Building settlement.
The Staff agrees with the contention that the Adminstration Building example represents information initially withheld from NRC. This information was known to the Applicant and was clearly relevant to the full understanding of the Diesel Generator Building settlement.
Q . 12. What is the NRC Staff response to Item 6 of Stamiris' supplement to Contention l?
A. Item 6 refers to " false statements" discussed in the April 3,1979 Keppler - Thornburg memorandum ( Attachment 15) and the June 13, 1979 Thornburg - Thompson memorandum ( Attachment 16)
l
- s. <
1
, l
, The significance or " materiality" of these FSAR statements to NR's review is described in D. Hood's memorandum to file dated August 9,1979, (Attachment 17), As indicated therein,' these other statements would not or could not have had.an influence upon a safety conclusion of the NRR staff. Rather, these other statements were viewed as an indicator of poor quality assurance performance.
e I
, .- . , . .--.., - - -- , . = , - - - - , , - - , - . - , . , .
l 1
3 4 Attachment 1 l l
DARL S. HOOD I
OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION PROFESSIONAL QUALIFICATIONS I am a Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation. I am responsible for nanaging licensing activities by the.Comission with respect to "idland Plant, Units 1 and
- 2. .
I have served in the position of Project Manager with the Comission since August 1976. This position provides for the managing of radiological. safety reviews of applications for licenses and authorization to construct or operate light water nuclear power plants. ,
As < of April 1980, the position also provides for the nanaging of the environmental reviews of such applications. I assumed responsibility for (tidland Plant, Units'1 and 2, when the application for operating licenses was tendered in August 1977. Other nuclear plants for which I have previously served in this capacity are the standardization design of Westinghouse which is designated RESAR-414 (Docket STiiS0-572), Catawaba Nuclear Station, Units 1 and 2 (Dockets 50-413 and ~50-414), and River Bend Station, Units 1 and 2 (Dockets 50-458 and 50-459).
Between June 1969 and August 1976 I held two sequential positions within the Nuclear Power Systems Division of Combustion Engineering, Inc.
(C-E) at Windsor, Connecticut. After flarch,1973, I was Assistant Project flanager for the Duke Power Project. This position provided assistance in directing all efforts by C-E to design, f abricate, purchase and license the nuclear steam supply systems, reactor core, and associated auxiliary systems for Cherokee Units 1, 2 & 3 and Thomas L.
Perkins Units 1, 2 & 3. The position assured that all aspects of the contracts were net and that safe and reliable systems were provided to the required schedule and at a reasonable profit to C-E. I assisted Duke Power in preparing the Preliminary Safety Analysis Report (PSAR) and provided for all C-E licensing support for these units. I also provided coordination of all other nuclear plants referencing the C-E Standard ,
Safety Analysis Report to assure compatibility with C-E standard reference design. Until fiarch,1973, I was a Project Engineer in C-E's
, Safety and Licensing Department and was responsible for licensing of nuclear power plants. I coordinated the preparation of the tiillstone Unit 2 PSAR and FSAR and the Calvert Cliffs Units 1 & 2 FSAR and interfaced with NRC, the utility, architect engineer and all C-E functional departments on licensing support matters. I ensured that NRC criteria, standards, and guides were incorporated into the nuclear steam supply system design.
i o .
l l
.2- 1 Setween August 1966 and June 1969, I was a Nuclear Safety and Radiation Analysis Engineer in the fluclear Safety Unit, fluclear Division of the Martin Marietta Corporation at Baltimore, Maryland. The purpose of this position was to perfom hazard evaluations for nuclear power sources applied in space missions. My primary duty was to detemine public exposure to radiation for malfunctions occurring during the intended mission. I also determined means by. which the hazard potential for nuclear space systems could be mitigated to the extent that nuclear safety criteria were met. I conducted research with regards to the development of suitable criteria for permissable exposure levels and their probabilities, taking into account the depen.dence of acceptable risk on the, benefit to be derived. iiy primar SNAP 29 (Systems for Nuclear Auxiliary Power)y ass!gnment project. My evaluationswas with the of this nuclear power source included the fomulation and application of computerized models for the transport of fuel released at high altitudes, in deep ocean and in shallow waters. I derived models for these release areas to incorporate che activity into human food chains and determined the expected ingestion dose, the number of people involved and the exposure probabilities. Inhalation dose was determined for radioactive fallout from the high-altitude release. -
Between February 1965 and August 1966 I was a fluclear Quality Control Engineer within the Electric Boat Division of General Dynamics at Groton, Connecticut. The purpose of this position was to provide control of quality for naval reactor systems, components, and shielding during the construction or overhaul of submarines by this shipyard. My primary area of responsibility was shielding. Duties included establishing procede s for the inspectior, of fabrication and installation of lead and polyethylene shielding, and resolving problems in complying with these or other shielding procedures. The position required a knowledge of nuclear theory, S5W system design, Bureau of Ships. contract and design requirements, non-destructive testing techniques, and quality control requirements.
Between November 1963 and February 1965, I was an Aeronautical Engineer for Nuclear Propulsion and Power at the George C. Marshall Space Flight Center, National Aeronautics and Space Administration 1n Huntsville, .
Alabama. I perfomed investigations of the nature and magnitude of the nuclear radiation environment, shielding systems and safety systems associated with proposed nuclear space vehicles for candidate space missions.
Between November 1963 and college graduation in 1962. I held various positions including chief of a missile electronics training unit at Redstone Arsenal, Alabamat student at the U.S. Amy Signal Officer's Orientation Course at Fort Gordon, Georgia; and fiarine Engineer for ordinance and special weapons within the Design Division of the Norfolk Naval Shipyard, Portsmouth, Virginia.
g -
4 , - .n,- .n x ...-o ,w- ,, , -
'h' I recaived a Bachelor of Science Degree in Nuclear Engineering frora North Carolina State University in 1962. . I am a member of the Health Physics
-a Society.
h
/
C 0
e
'(<
h
's
+
,T
$ ee l
t l
l n
l l
l l
. -- , . . . - - - ~ - - . - , - - , - - - - . - - - - - - - -- - -- ~ - , - - - - - - - - ~ ~ - -
, , ATTACHMuti i 1
.4 EUGENE J. GALLAGHER OFFICE OF INSPECTION AND ENFORCEMENT l U.S. idCLEAR REGULATORY COMMISSION
)
PROFESSIONAL QUALIFICATIONS l
I am a Civil Engineer in the Division of Resident and Regional Reactor . I' Inspection, Reactor Engineering Branch, Office of Inspection and Enforcement.
TI received a Bachelor of Engineering Degree in Civil Engineering from
. Villanova University in 1973 and a Master of Science Degree in C(vil/ Structural Engineering from Polytechnical Institute of New York in 1974, I am a registered Professional'Engir.eer in the States of Illinois (#37828), Florida (#29114) and Louisiana (#16376). I am a member of the ~ Araerican Society of Civil Engineers, American Concrete Institute and Tau Beu Pi National Engineering Honor Society.
In my present work at the NRC, I provide technical assistance in the area ,
of civil engineering to Regional offices and resident inspectors with particular emphasis on the design and construction of reinforced and prestressed concrete structures, foundations, structural steel buildings and in structural . testing and surveillance. In addition, I provide technical ~ input for the . development and interpretation of industry codes ,
standards and regulatory requirements relating to inspection activities.
From 1978 to 1981 I was a member of the NRC Region 3 inspection staff responsible for the inspections of civil engineering aspects of plants under construction and in operation. This included the Inspection of ,
laboratory and field testing of concrete,. steel and soils materials, earth embankments and dams, material sources, piping systens and reinforced and prestressed concrete structures. In addition, a review of raanagement controls and quality assurance programs were perfonned at plants under construction. I participated in approximately 90 inspections of reactor facilities.
Prior to joining the NRC Staff I was employed by EBASCO Services, Inc. in New York City from 1973 to 1978. I perfonned designs of reinforced concrete and steel structures, design of hydraulic and water supply systems and preparation of specifications for construction. From 1976 to 1978, I was the civil resident engineer at the Waterford 3 Nuclear Plant site responsible for providing technical assistance to construction.
During 1972 and 1973 I was employed by Valley Forge Laboratory in Devon, ,
4 ' PA performing inspection and testing on concrete, steel and soil '
materials. ,
I
~
b j ..
2 ADDITIONAL NRC TRAINING Fundamentals of Inspection, NRC, February 1978 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
BWR Fundamentals Course, NRC, March 1978 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
Concrete Technology and Codes, Portland Cement Assoc., May 1978 (80-hours)
Quality Assurance Course, NRC, August 1978 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
Nondestructive Examination and Codes, Rockwell Int'1., August 1978(120 !
hours)- .
PWR. Fundamentals Course, NRC, November 1970-(40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />) 1 Welding Metallurgy, Ohio State University, September 1980 (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) l 1
D e
M e
l JEFFREY K. KIMBALL GEOSCIENCES BRANCH, P-314 .
)
DIVISION OF ENGINEERING '-" !
U. S. NUCLEAR REAGULATORY COMMISSION )
WASHINGTON, D.C. 20555 Ny.nameis Jeffrey K. Kimball. I am employed as a Seismologist / Geophysicist reviewer, Geosciences Branch, Division of Engineering, Office of Nuclear Reactor Regulation.
I received a B.S. degree in Oceanography from the. University of Michigan in 1977 and a M.S. degree in Geology from the University of Michigan in 1979, with a speci,alty in seismology and geophysics.
I have been employed by NRC since May 1980 as a Seismologist / Geophysicist reviewer as applied to the evaluation of applications for construction and operation of nuclear facilities, and to determine the thoroughness of this information for defining the seismic hazard for which facilities must be designed. Since joining the Nuclear Regulatory Commission staff, I have participated in the licensing activity for approximately ten sites.
From 1977 to 1980, I was a research assistant and teaching assistant at the University of Michigan. My activity as a research assistant included seismic data compilation studies for the U. S. Geological Survey and data analysis aod operation of a nine station seismic network. My M.S. thesis work involved a study on surface wave dispersion of the Atlantic Ocean Basins and has been presented at national meetings of professional societies and published in a professional journal. Teaching assistant experience consisted -
.of helping teach both introductory and advanced geology field courses in Wyoming for two summers and an introductory geology laboratory class at the University of Michigan.
I am a member of the American Geophysical Union and the Seismological Society of America, and have co-authored 7 publications including abstracts of pre-sentations to professional societies and NUREG documents.
O g 0
Sqg e
. !E )
1 i
. . ~ . _ * . . ,
l he-- +-
T e t ye*--+u- e m- % w -r dw w wv-
~
1 e e *
\
Responses to NRC Questions Attachment 2 Midland 152 Question 361.4 (2.5)
You conclude' that the Michigan basin fits the Appendix A to 10 CFR Part 100 description of a tectonic province. Yet the basin is characterized by the same geologic structural features and has essentially the same geologic and tectonic history as the remainder of the Central Stable Region (Eardley, 1962).
- a. The Precambrian basement complex in the Michigan basin does not appear to be unique with respect to the surrounding region.
b.- The Precambrian crustal features, the Keweenawan rift zone (see liinze and others, 1975, on the Mid-Michigan gravity anomaly associated with the Keeweenawan rlf t zone), and Grenville Front transect the boundary of the 12 basin.
- c. The subsidence and deposition in the basin occurred concurrently with subsidence, arching, and doming in ether parts of the Central Stable Region during the Paleozoic.
Please provide information demonstrating the distinct characteristics of the Michigan basin which distinguish it from the Central Stable Region. Include geophysical and remote .
( sensing data which may reflect structural characteristics of the Basin'and adjoining portions of the Central stable Region.
Responso Subsection 2.5.1.1.3.1 has been revised in response to this 1" question. l In addition to the information presented in revised Subsection 2.5.1.1.3, various investigations directed at evaluating inferred structures beneath Lake Michigan were recently completed by 15 Wisconsin Electric Power Company relative to the Haven, Wisconsin, project. The results of this work are to be submitted to the NRC by Wisconsin Electric Power Company in 1979.
0 Revision 15 QGR 2.5-11 11/78 g
, ~ . _ _ ,_ . . . . . . , _ _ . _ _ . . . __ . . _ ._ .. - . _ _ .~. -
MIDLAND 1&2-FSAR 2.5.1.1.2.4 Cenozoic Pleistocene unconsolidated surface deposits rest unconformably on I the Mesozoic and Paleozoic rocks throughout the lower peninsula of Michigan. These extensive surface deposits are attributable to the last major period of continental glaciation, the Wisconsin stage, active in Michigan from 50,000 to 13,000 years ago.
During the numerous periods of glacial advance and retreat of the Wisconsin stage, drift of various types was deposited across the state, including till, outwash, and glaciolacustrine deposits.
Figure 2.5-2 shows the surface deposits present in the region.
Glacial deposits across the state range in thickness from only a few feet in the northern portion to over 400 feet in the central portion of the state. Beneath the site the glacial drift is approximately 350 feet thick and consists primarily of outwash and till. A detailed discussion of the glacial deposits at the site is pre,sented in Subsection 2.5.1.2.2.
2.5.1.1.3 Regional Geologic and Tectonic Structures The north central United States is situated in the central portion of the continental craton of North America, the stable core of the continent. The craton is composed of two major tectonic divisions: the Precambrian Canadian Shield to the north 5 and the Paleozoic age sedimentary strata to the south.(2) The contact between thene major divisions is roughly located along the Canadian-United Ftates border. To the north a complex mixture of metam.'rph-.c, igneous, and sedimdhtary rocks of the -
Canadian Shield is present in most of the eastern two-thirds of Canada. These' rocks have been stable for at least the last 500 million years and contain some of the most ancient rock units exposed on earth. To the south the geologic structure of the Paleozoic portion of the craton is characterized by essentially flat lying sedimentary rocks modified only by a series of broad shallow structural basins separated by low arches. These sedimentary strata of the craton are present under the central United States.
i v' 2.5.1.1.3.1 Michigan Basin i
l Michigan's entire lower peninsula, as well as part of the upper peninsula, eastern Wisconsin, northern Illineis, Indiana, Ohic, and parts of Canada, are underlain by a broad, shallow, structural depression tectonic province with an area of approximately 122,000 square miles which is known as the Michigan Basin (see Figure 2.5-6). The Michigan Basin underwent nearly continuous subsidence and deposition from the Cambrian through 14 Pennsylvanian Periods m (see Subsection 2.5.1.1.2). The general shape of the existing basin was first formed in Ordovician time, and has remained fairly constant since the end of Niagaran (Silurian) time.m2) The maximum accumulation of sediments in the (see Figure 2.5-5).
center of the basin is over 14,000 feettsu Revision 14 2.5-5 10/78
MIDLAND 1&2-FSAR The forces which produced this nearly~ continuous subsidence for a pariod of almost 300 million years were undoubtedly different than those beneath the surrounding structural highs or the I Canadian Shield.
The arches and domes surrounding the Michigan Basin remained as ecsentially stable areas throughout most of the Paleozoic. The Wisconsin dome to the west was a structural high at the beginning of the Cambriants2) , whereas the Michigan area was part of a large basin which included the Illinois Basin.ns) Lockett(s21 indicates the structural highs which form the boundaries on the couthern half of the Michigan Basin were more'or less positive features throughout the entire Paleozoic' era. GreenW31 indicated that. the positive regional structures in the Indiana-ohio area are due to subsidence of the Appalachian, Michigan, and Illinois Basins, rather than uplift between the ,
basins. Eardley.533 indicates that the Kankakee and Findlay Arches formed during the Ordovician.
GreenWW discusses the Cincinnati Arch geologic province and states:
Subsidence in the Michigan basin began near the close of Niagaran (middle Silurian) time.
Before that subsidence, the area of Indiana, $g ohio, and southern Michigan is considered to have been part of a sea floor which sloped gently toward the southeast from Illinois to Pennsylvania and Virginia. This relatively (' -
flat sea floor may be considered as having then been a structural shelf.
Green also indicates that a broad shelf area over 150 miles wide
' oxisted between the Illinois and Michigan Basins until Mississippian time. There is general agreement that the " arches" ,
between the Illinois, Michigan, and Appalachian ba.ains have
! resulted from " resistance to subsidence" rather than from actual uplift.
Development of the Michigan' Basin was most rapid during the upper Silurian. About 30% of the total Paleozoic sediments was accumulated during this time. Only small patches of lower Devonian sediments are known in the basin (so and the area was probably a low land mass during most of this time. During middle end upper Devonian, deposition resumed and over 3,000 feet of sediments accumulated in the central part of'the basin.
Dapsotion continued into the Mississippian without interruption.
.There was a short break in sediment accumulation during mid-Mississippian, and another longer break in late Mississippian which continued through mid-Pennsylvanian time. Ham and Wilson (so state:
Revision 14 2.5-6 10/78
_.---_._.__.__.__._._..._..___..._.________._______.____.--.m
l MfDLAND l&2-FSAR l l
clearly the most widely developed and profound Paleozoic unconformity of the craton occurs I below strata of Early Pennsylvanian age.
+
l Most'of the folding related to the development of the small anticlinal features in'the Michigan Basin have been assigned by Ells 51 to this late Mississippian and early Pennsylvanian activity.
Since Pennaulvanian time, the Michigan Basin has apparently been a low land mass subject to erosion. S.ome localized deposition occurred in the Jurassic,.but this deposition' appears to have occurred in low-areas on the. eroded Paleozoic surface.*
As discussed in Subsection 2.5.2 of the FSAR, only eight earthquakes of' epicentral' intensity greater than III (Modified Mercalli~ Scale) have been located on the southern peninsula of Michigan in the past 350 years. Around the basin margin, but within the Michigan Basin area as outlined in Figure 2.5-6, an additional.14 earthquakes of epicentral intensity greater'than III or magnitude greater than 3.0 have been recorded. None of the' events located-within the Michigan Basin have had' intensities greater than VI. There is no known geological control for the distribution-or occurrence of'the earthquakes within the basin.
. It'has been suggested that seismic activity in this area may be
'related to crustal rebound resulting from the retreat of glacial 14 ice since Pleistocene time.553
~
( Gravity and magnetic data (Figures 2.5-86 and 2.5-9) indicate that several types of Precambrian basement rocks occur beneath the Michigan Basin. The. zoning of these rocks into " structural provinces" and evaluation of their significance to the development of the basin structure have been discussed by several authors le4. ss, su Distribution of basement rocks into zones or
" provinces" by isotopic ages 5 71 has been modified5 " based on i ,
interpretation of-gravity and magnetic data and available drill hole data and is shown in Figure 2.5-87. The basement
" provinces" of Hinze WH are very similar to the areas of basement rocks shown by Ham and Wilson.543 The mid-Michigan gravity and magnetic anomaly have been correlated with Keeweenawan. igneous activity (1.05 to 1.15 billion years).
Isotopic age determinations for samples from drill holes in southeastern Michigan indicate the basement rocks in that area rang from 0.8 to 1.1 billion years. They have been correlated with the Grenville province of southern Ontario. No isotopic age determinations younger than 0.8 billion years have been recorded.
. Development of the Michigan Basin most likely occurred after activity along Precambrian structural zones had ceased. Movement on these zones apparently had no effect or control on the development of the basin.
Some' movement along zones of structural weakness wi' thin the Precambrian basement during-Paleozoic time has been postulated by
, Ells,81 Hinze,5U and others, but there is no direct evidence 2.5-6a Revision 14 10/78
. _ . _ . . _ . - - - - _ . - - . _ . - . . _ - . - - . - . - = -
I MIDLAND 1&2-FSAR of differential movement within or between basement provinces cince the Precambrian. In discussing the relationship of the Precambrian basement to structures within the Paelozoic (.
l scdimentary cover, Hinze states:
In general, the structural (anticlinal) l petroleum reservoirs in the Southern Peninsula trend east-southeast to southeast, paralleling the Penokean structural trends and the mid-Michigan and southwest Michigan anomalies south of 43*30'N lat. This' correlation suggests a strong relation between the l basement and intrabasin structures, perhaps as ,
a result of movement along Precambrian basement zones of weakness caused by sinking of the basin or externally applied stress fields. Hinze and Merritt (1969) cited
' specific examples of these relations and, as they pointed out, some intrabasin structures may be related to topographic relief on the basement surface. However, this interpretation does not rule out the presence of intrabasin structures that are unrelated to the basement.
In general, the anticlinal structures within the Michigan Basin I" are small, and there is insufficient data to determine the relationship, if any, between these flexures and the basement ,_
rocks. If, however, these anticlinal structures were formed by (
movement along basement zones of weakness during late Mississippian /early Pennsylvanian time (the date of folding indicated by Ells, m ) then they have been essentially stable since that time, or for over 300 million years. There are no indications that the basement rocks have had any effect on basin or intrabasin structures sinca the close of the Paleozoic, about 230 million years ago. Therefore, the extent of lithologic or ctructural provinces within the Precambrian basement (such as the Ksweenawan rift zone) are not relevant to the delineation of the Michigan Basin Tectonic Province.
The Michigan Basin has been largely isolated from the tectonic activity which has affected other major basins in the Central Stable Region. It is located deep within the central craton area and is surrounded by features which have remained essentially stable since the Ordovician. The late Paleozoic activity, which no strongly affected the Appalachian Basin to the southeast and the cuachita fold belt to the southwest, is also reflected in the d;velopment of the LaSalle anticlinal belt in the Illinois Basin,M uplifts in Texas and Oklahoma,(s* and the uplift of the Nemaha Ridge in eastern Kansas.m2) However, the effect of this widespread late Paleozoic actitity in the Michigan Basin was minor. At most, it may have caused the formation of small anticlinal folds trending generally northwest-southeast.*
l 2.5-6b Revision 14 l 10/78
. . _ _ _. ~
MIDLAND 1&2-FSAR The period of slight tectonic activity within the Michigan Basin roughly correspond in time with tectonic activity elsewhere
/ within the central Stable Region, but this is also true for tectonic events in orogenic belts outside the Central Stable Region (i.e., the Appalachian Basin and the Ouachita fold belt).
The markedly:different magnitude of tectonic activity in Illinois, Kansas, Nebraska, Texas, and Oklahoma from that experienced by the Michigan Basin combined with the size of the basin (over 120,000 square miles). supports the concept o:f the Michigan Basin being a tectonic province as defined in 20 CFR 100, Appendix A. The basin is and has been a persistent, qq distinct region which has been geologically and structurally distinguishable from the remainder of the Central Stable Region
- since.the upper Silurian over 400 million years ago. There is nothing in the seismic history of the region which suggests that the Michigan Basin should not be considered to be a tectonic province. .The seismic history of the Michigan Basin clearly demonstrates that it is a region which has experienced very few events in the past 350 years, the period for which records are available. All of the events which have occurred were small (maximum intensity VI). All the data indicate that the Michigan Basin can be readily separated from the remainder of the Central Stable Region for the purposes of evaluating the potential for future vibratory ground motion.
5 2.5.1.1.3.2 Intrabasin Structural Features 2.5.1.1.3.2.1 Folds Within the Michigan Basin, numerous small anticlinal flexures are present, trending generally northwest-southeast, and occurring throughout the basin (Figure 2.5-7). The knowledge of the existence of these flexures is based mostly upon data obtained from exploratory drilling for oil, primarily in Silurian and Devonian age strata.
These fold structures are described by Ells in reference to a 1930 paper by Newcombe as:
.. . irregular, elongate plunging anticlines with local domes superimposed. In cross section the folds were said to be asymmetrical with the strong dip toward the basinward side . . . .
The dips off-structure were shown to vary in the different fields from 125 to 200 feet per mile, and from 50 to 75 feet per mile on the gentle side.
These northwest-southeast trending flexures are best defined in the eastern, southeastern, and central portions of the Lower 5 o ' Peninsula. I 2.5-6c Revision 14 10/78
l MIDLAND 1&2-FSAR l l
The origin of these intrabasin structures is not known, and ccveral mechanisms have been postulated. While the method of ctructural development is not fully understood, there is general Egreement on the age (Paleozoic) of the features. Elle 5
(
cummarizes the type and origin of these structures:
4
(
s
/
l l
l l
(.
t 2.5-6d Revision 14 10/78
1 Respontes to NRC Questions Attachment 3 Midland 152 Question 361.4 (2.5)
You conclude that the nichigan basin fits the Appendix A to 10 CFR Part 100 description of a tectonic province. Yet the basin is characterized by the same geologic structural features and has essentially the same geologic and tectonic history as the remainder of the Central Stable Region (Cardley, 1962),
- a. The Precambrian basement complex in the Michigan basin does not appear to be unique with respect to the surrounding region.
- b. The Precambrian crustal features, the Keweenawan rift zone (see Hinze and others, 1975, on the Mid-Michigan grav.ity anomaly asse-iated with the Keeweenawan rif t zone) , and Grenville Front transect the boundary of the 32 basin.
- c. The subsidence and deposition in the basin occurred concurrently with subsidence, arching, and doming in other parts of the Central stable Region during the Paleozoic.
Please provide information demonstrating the distinct characteristics of the Michigan basin which distinguish it from the Central Stable Region. Include geophysical and remote r sensing data which may reflect structural characteristics of the L Basin and adjoining portions of the central Stable Region.
Response
Subsection 2.5.1.1.3.1 has been revised in response to this question. ! 34
! l 30 l
l l
l l
l t
l Q&R 2.5-11 Revision 30 i
t' 10/80 l
l
Responses to NRC Ouestions - Attachment 4 Midland 1&2
.Qunstion 361.5 (2.5)
IThn' basis for . your definition. of the safe shutdown earthquake rasts1upon the acceptance of the Michigan Basin as a separate tectonic' province. The. staff has been reluctant to accept subdivision of ;the Central Stable Region into smaller tectonic
. provinces. - Provide additiona1'information, such as.a comparative analysis of historic and instrumental seismicity, that would.
permit acceptance.of a lower reference acceleration than that 12 normally used for the Central Stable Region (0.20g). Include in your analysis all those events, listed in " Seismic Disturbances in
~
Michigan" Circular 14, Geological Survey Division, Department of Natural Resources, State of Michigan (1977) or provide a rationale for their exclusion. . The' analysis should compare the 1 seismicity' of' the region within 200 miles of the site with other ,
similar sized areas in the Central stable Region.
.Rasponse
'It is our opinion that the Michigan Basin is an arca that, for
-ths. purpose of evalucting the SSE at the Midland' site in the is- :
context . of ' 10 CFR - 100, Appendix A and Regulatory Guide 1. 70,
. suf ficiently distinctive,, when both its geologic 1md seisraic characteristics are considered, to justify its acceptance as a convenient' and : realistic tectonic. or seismotectonic province.
With regard to seismic considerations alone, it is difficult to (-
sen how reluctance to accept subdivision of the Central Stable-Region into smaller tectonic provinces.can be based on historical and instrumental seismicity. . Several zones of clearly.
distinguishable, relatively high seismic activity occur within ths Central Stable . Region. However,.no such zones occur within the Michigan Basin tectonic province which, on' the contrary, has
' experienced only a few scattered small events in historic time; gg the maximum intensity of these was only 'VI (Modified Mercalli Scale). All' earthquakes in the Central Stable Region larger than Intensity VII have.been associated with geologic structure, except for-the Anna, Ohio, activity (e.g., Marble Hill Nuclear Generating Station Units 1 and 2, Safety Evaluation Report, 1972). However, the clustering of historical seismic activity-near Anna argues strongly for the association of localized structure or structures with'these events as well.
Additionally, several workers o .2) have identified subsurface
. faults'in the basement'in this area. The proximity of these
' faults to three reliably located earthquakes, and the epicentral uncertainity of other- nearby historical earthquakes, has led
.Maukm tospeculate that the Findlay and Anna-Champaign faults may be the sources of the' seismicity for this part of western Ohio. He also states W tha t , although the data are now inconclusive, it is strongly suspected that the Anna sciswic zone's seismicity is related to these fault systems (which includes the Auglaize and the Logan-Hardin faults). On the basis ~ / ,
Revision 14 10/78 QSR 2.5-12 e ++ t' t g 'T m ei g i ff + W3- t-freg yrtareW g wg re '
y+'*s-y-+ste-o+e+w- eywee+ ym st ew---y e r v ic e e se e s,,e.yes-,wa.1=aw*e=--- =-ar -r sees + .<wa,e . em. w--wm-,-v~r--wwe- -=++,-+i=* *e*- *a -4.,-.= ---wa.e--m------w- ,-
. .- . . ~. . - -. . . - .- ._. ,
f.- ..-
Responses to NRC Questions l Midland 162.
of thisLsuspicion, the seismograph-and gravity networks in the area have been restructured accordingly.
~ Recent studies by Algermissen,W Nuttli,5- Hadley and Divine , m ' Algermissen and.Perkins,* and Donovan.et al,* done with the intent.of providing guidance for seismic design or engineered , structures, contain information applicable to the Michigan: Basin and the Midland site area. These studies are all somewhat different in intent-and all show somewhat different results. However, they all have three important features in
- common
- (1) they are all based on both historic seismicity. and
! geologic considerations; (2) all show significant differences in seismic hazard: characterization within the Central Stable Region; and (3) all show the area around.the Midland site to be among those . areas characterized by the lowest seismic hazard level within the. Central. Stable Region. ' No later studies are known that call these general features. of the Central Stable Region and tWe site area into questions on the basis of more recent seismicity. In particular, the updated ; earthquake list in the Midland FSAR does not alter the characterization of the Midland site area asfa' seismically quiet area within the seismically differentiable ~ Central Stable Region. In our opinion, any new -
analysis.using this data, such as one comparing the seismicity of
.the region within 200 miles of the site with other similar sized areas in the Central: Stable Region, would show very similar
, , results. y4
-(.
As requested, all: vents listed in Circular 14, Seismic
~
Disturbances in Michigan, Geological Survey Division, Department
.of Natural Resources, state of Michigan, have been considered.
The FSAR has been amended to reflect this consideration. Of the 34 events listed in this publication as occurring in Michigan since 1872, 22 of them are outside the 200 mile radius site region, or have an intensity that is either too small (sIII) or which is' unknown and presumed to be too small to be of interest.
These events are excluded from further consideration in agreement with the approach taken in the FSAR.
Of the twelve remaining earthquakes listed in Circular 14, seven were included ~ in FSAR Table 2. 5-2. The intensities listed in the FSAR for these seven events are all greater than or equal to the corresponding intensities listed in Circular 14. Coordinates are given in the _FSAR for five of the seven events and they agree well with those given in Circular 14. The remaining two events
- (May 18, 1945, and February 2, 1967) were not given precise coordinates' in the FSAR but coicide in location with the coordinates in Circular 14. The maximum intensity of the remaining five events in Circular 14 is r'. They are discussed-briefly below.
~
.0ctober. 10,,1899, St. Jose (42*05'N, 86*31'W, f.
intensity IV) . Docekal(M) ph, Michigan
-contains this account: "St. Joseph,
-Michigan, felt a distinct shock followed by lesser shocks. The
' Revision 14 QSR 2.5-13 10/78
~.. ~ ,_ _ _.. _..._._ _ _ _ _ _._ _ ._ _..___ _ _ _ .
Responses to URC Questions Midland 162 southern part of the city reported many dwellings swayed, windows rattled, and many families abandoned their homes. The earthquake ,
was clearly felt for a radius of 15 miles. Kenosha, Wisconsin, reported a slight shock which was plainly felt in all parts of the city". It should be noted that Kenosha, Wisconsin is roughly 75 miles from St. Joseph, Michigan, and that this event was not l report felt in Grand Rapids which is about the same distance in the opposite direction. At any rate, this intensity IV event appears genuine and has been included in the list of earthquakes i felt within the site region. l February 22, 1918, Morrice, Michigan (42'51'N, 84'11'W, intensity IV). "An abrupt bump was felt at Morrice, Michigan. A first crack 150 feet long and 4 feet deep with numerous diverging cracks was reported."UO' This event has been added to the earthquake list.
March 13, 1938, Detroit Michigan (42 22'N, 83 10'W, intensity IV).z "A local shock jarred western Detroit and portions of Ontario bordering the Detroit River. "001 U.S. Eat chquakes!SU includes this event which is recorded as a " slight shock" without I4 intensity designation.
November 16, 1944, and December 10, 1944, Escanaba, Michigan (both at 45 44'N and 87005'W). These two earthquakes in the northern peninsula region are taken from Docekal's: 0 03 work. The , _
former, listed as intensity II-III (without reference to specific _
sources) is described as, "A light shock was felt by several persons at Escanaba, Michigan. A barograph recorded the shock."
The latter is listed as intensity IV and is described as, "in a shock at Escanaba, Michigan, caused dishes to shake and rattle. "
The November 16, 1944, event is listed in U.S. Earthquakes n2) without intensity; the December 10, 1944, event is not recorded in that j ournal.
l Consideration of these five earthquakes does not alter the l conclusions reached in the FSAR. With the exception of the
! February 22, 1918, Morrice, Michigan, earthquake, the events added from Circular 14 all lie 100 or more miles away from the site. Addition of the events listed in Circular 14 increases the total number of earthquakes with intensity greater than III known to have occured within the site tectonic province, but it does not alter the maximum historical intensity at the site (estimated l
to be V), nor increase the maximum historical intensity (VI) within the Michigan Basin tectonic province.
"I M.L. Kiefer and J.S. Trapp, Report: Interpretation of __ .
mechanisms for the Anna, Ohio earthauakes for the Marble Hill _
Generacing Station, Public Service, Indiana, Dames and Moore, 1975 Revision 14 QSR 2.5-14 10/78
Responses to NRC Questions Midland 1&2
? mStone and Webster Engineering Corporation, "Paulting in the Anna, Ohio region,"" PSAR, Wisconsin Utilities Project,_
Koshkonong Nuclear Plant, Units 1 & 2, Amendment 12, Appendix 21, 19,7,6 mF .J. !! auk , " Geophysical Investigations of the Anna, Ohio Earthquake Zone," NUREC Technical Report contract No.
NRC-0 4-7 6-19 2, Annual Progress Report, August 1, 1978, 1978
- T.J. Mauk, " Geophysical Investigations of the Anna, Ohio Earthquake Zone," NUREG Technical Report Contract No. AT(49-24)-
0192 Quarterly Progress Report, May 1, 1977 - November 1, 1977, 1977 mS.T. Algermission, " Seismic Risk Studies in the United States,"
Proceedings of the Fourth World Conference on Earthquake Engineering, Santiago, Chile, 1969 8 0.W. Muttli, Design Earthquakes for the Central United States, U.S. . Army Engineer Waterways Experiment Station Miscellaneous Paper S-73-1, 1973 W J.D. IIadley, and J.F. Devine, Seismotectonic Map of the 14 Eastern United States, U.S. Geologic Survey, publication MF-
. 620, 1974
{ *S.T. Algermissen, and D.!!. Perkins, A Probabilistic Estimate -
g of Itaximum Acceleration in Rock in the Contiguous United States U.S. GeoE6gic Survey, Open File Report 76-416, 1976
- H.C. Donovan, B.A. Bolt, and R.V. Whitman " Development of Expectancy flaps and Risk Analysis," American Society of Civil Engineers annual convention, Philadelphia, Preprint 2005, 1976 UGDocekal, Earthquakes of the Stable Interior, with Emphasis on j
the !!ideontinent (vol 1 and 2), University of Nebraska, PhD l
thesis University Microfilms, 1970 1
UUU.S. Department of Commerce, U.S. Earthquakes 1938, 1940 m2) U . S . Department of Commerce, U.S. Earthquakes 1944, 1946 l.
l A.J. Eardley, Structural Geology of North America, Second i Edition !!arper Row, 1962 I
l Revision 14 Q&R 2.5-15 10/78 l
Responses to NRC Questions Attachment 5 Midland.1&2
. Question 361.5 (2.5) (
-The: basis for.your definition of the safe shutdown earthquake rests upon the acceptance of'the' Michigan Basin as a! separate tectonic-province. The staff - has been reluctant to accept subdivision of the Central Stable Region into smaller tectonic
. provinces. . Provide additional information, such as a. comparative analysis of historic and instrumental seismicity, that would .
1 permit acceptance of a lower reference' acceleration than that 12 normally used for the Central Stable Region .(0.20g) . Include in your analysis all those' events listed in " Seismic Disturbances in
- Michigan". Circular 14, Geological' Survey Division, Department of
'Matural Resources, State of Michigan (1977) or provide a rationale for their exclusion. The analysis'should compare the seismicity of- the region within 200 miles of the site with other similar sized areas in the Central ~ Stable Region.
Response
It is our opinion that. the . Michigan Basin is an area that, for the purpose of evaluating-the SSE at the Midland site in the context of 10 CFR 100, Appendix A and Regulatory Guide 1.70, is sufficiently distinctive, when both its geologic and seismic characteristics.are considered, to justify its acceptance as a convenient and realistic tectonic or seismotectonic province.
- With regard to seismic considerations alone, it is difficult to I
see how. reluctance to accept subdivision of the Central Stable (~
Region into smaller tectonic provinces ' can be based on historical and instrumental seismicity. Several zones of clearly distinguishable, ~ relatively high seismic activity occur within the Central' Stable Region. 'However, no such zones occur within
' the Michigan Basin : tectonic province .which, on the contrary, has experienced only a few scattered small events in historic time; 34
. the maximum intensity of these was only VI (Modified Mercalli !
~ Scale). All earthquakes in the Central Stable Region larger than Intensity VII hsve been associated with geologic structure, except for the Anna, Ohio,-activity (e.g., Marble Hill Nuclear Gsnerating Station Units 1 and 2, Safety Evaluation .
- . Report, 1972). However, the clustering of historical seismic l activity near Anna argues strongly for the association of I localized
- structure or structures with these events as well.
' Additionally, several workers 1b2r have identified subsurface faults in the basement.in this area.. The proximity of these faults l to three reliably located earthquakes, and the epicentral uncertainity of- other nearby historical earthquakes, has led Mauk* to speculate that the Findlay and Anna-Champaign faults l30 may be the sources ~of the seismicity for this part of western Ohio. He also states W tha t , although the data are now
. inconclusive, 'it is. strongly suspected that the Anna seismic 14 zone'siseismicity is related to these fault systems (which !
- includes. the . Auglaize and the Logan-Hardin faults) . On the basis k
QER 2.5-12 Revision 30 10/80
l.,_.
, .. s Responses to_NRC Questions Midland 152 of this suspicion, the seismograph and gravity networks in the area have been restructured accordingly.
Recent studiesJby Algermissen,WI Nuttli,M3 Hadley and Divine,873 Algermissen and Perkins, mL and Donovin et al,Ni done
'with the intent of providing guidance for seismic design or engineered structures, contain information applicable : to the Michigan Basin and the Midland site area. These studies are
' all somewhat'different in intent and all show somewhat different results. However, they all have three important features in common: . (1) .they are all based on both historic seismicity and L geologic considerations; . (2) all show'significant differences in seismic hazard characterization within the Central Stable Region; and f(3) . all showithe arca around the Midland site to be among those areas characterized by the lowest seismic hazard level
- within the Central. Stable Region. 'No later studies are known that call these general features of the Central Stable Region and the . site area into questions on. the basis of more recent seismicity. In particular, the updated earthquake list in the Midland FSAR does not alter the characterization of the Midland site area as a seismically quiet area within the seismically differentiable Central Stable Region. In our opinion, any new -
analysis'using this-data, such as one comparing the seismicity of the region within 200 miles of the site with other similar sized areas in the Central stable Region, would show very similar
, results. }4
\
-As requested,-all vents listed in Circular 14, Seismic Disturbances in Michigan, Geological Survey Division, Department of Natural Resources, state of Michigan, have been considered.
The FSAR has been' amended to reflect this consideration. Of the
'34 events listed in this publication as occurring in Michigan since 1872, 22 of them are outside the 200 mile radius site region, or have an intensity that is either too small (sIII) or which is unknown and presumed to be too small to be of interest.
These events are excluded from further consideration in agreement with the approach taken in the FSAR.
Of- the twelva remaining earthquakes listed in Circular 14, seven were included in FSAR Table 2. 5-2. The intensities listed in dbe FSAR 'for these seven events are all greater than or equal to ' the
- corresponding intensities listed in Circular 14 Coordinates are given in .the FSAR for five of the seven events and they agree well with those given in Circular 14. The remaining two events (May 18, 1945, and February 2, 1967) were not given precise coordinates in the FSAR but coicide in location with the coordinates in Circular 14. The maximum intensity of the remaining five events in circular 14 is IV. They are discussed ,
-briefly below.
October 10,11899, St. Joseph, Michigan (42 35'N, 86 31'W, intensity IV) . DocekalDO) contains this account: "St. Joseph, Michigan, felt a distinct shock followed by lesser shocks. The Revision 14 QSR 2.5-13 10/78
Responsos to NRC Questions Midland 152 southern part of the city reported many dwellings swayed, windows rattled, and many families abandoned their homes. The earthquake g was clearly felt for a radius of 15 miles. Kenosha, Wisconsin, '
reported a slight shock which was plainly felt in all parts of the city". It should be noted that Kenosha, Wisconsin is roughly 75 miles from St. Joseph, Michigan, and that this event was not
-report felt in Grand Rapids which is about the same distance in the opposite direction. At any rate, this intensity IV event appears genuine and has been included in the list of earthquakes felt within the site region.
February 22, 1918, Morrice, Michigan (42 51'N, 84'11'W, intensity IV). "An abrupt bump was felt at Morrice, Michigan. A first crack 150 feet long and 4 feet deep with numerous diverging cracks was reported."UH This event has been added to the earthquake list.
March 13, 1938, Detroit Michigan (42*22'N, 83*10'W, intensity IV).z "A local shock jarred western Detroit and portions of Ontario bordering the Detroit River. "001 U.S. Earthquakes!"8 includes this event which is recorded as a " slight shock" without 14 intencity designation.
. November 16, 1944, and December 10, 1944, Escanaba, Michigan (both at 4 5 4 4 ' N and 87 80 5 'W) . These two earthquakes in the northern peninsula region are taken from Docekal's:" I wo'rk . The ,
former, listed as intensity II-III (without reference to specific '
sources) is described as, "A light shock was felt by several persons at Escanaba, Michigan. A barograph recorded the shock."
The latter is listed as intensity IV and is described as, "in a shock at Escanaba, Michigan, caused dishes to shake and rattle."
The November 16, 1944, event is listed in U.S. Earthquakes o2) without intensity; the December 10, 1944, event is not recorded in that journal.
Consideration of these five earthquakes does not alter the i conclusions reached in the FSAR. With the exception of the l
February 22, 1918,-Merrice, Michigan, earthquake, the events i
added from circular 14 all lie 100 or more miles away from the I site. Addition of the events listed in Circular 14 increases the total number of earthquakes with intensity greater than III known to have occured within the site tectonic province, but it does not alter the maximum historical intensity at the site (estimated to be V), nor increase the maximum historical intensity (VI) within the Michigan Basin tectonic province.
u1 M.L. Kiefer and J.S. Trapp, Report: Interpretation of __
I mechanisms for the Anna, Ohio earthcuakes for the Marble Hill. . .
Generating Station, Public Service, Indiana, Dames and l Moore, 1975 l
Revision 14 QSR 2.5-14 10/78 L - - - - _ .__ _ _ _
Responses to NRC Questions Midland 1&2
( mStono and Webster Engineering Corporation, "Paulting in the
~
Anna, Ohio region,"" PSAR, Wisconsin Utilities Proj ect, Koshkonong Nuclear Plant, Units 1 & 2, Amendment 122 hppendix-21, 1976
-WP.J. Ilauk, " Geophysical Investigations of the Anna, Ohio Earthquake Zone," tTUREG Technical Report Contract No.
NRC-0 4-7 6-1J 2, Annual Progress Report, August 1, 1978, 1978 Wr.J. :tauk, " Geophysical Investigations of the Anna, Ohio Earthquake - Zone," NUREG Technical Report contract No. AT (49-2 4)-
019; Quarterly Progress Report, May 1, 1977 - November 1, 1977, 1977 mS.T. Algermission, " Seismic Risk Studies in the United States,"
Proceedings of the Fourth 'World Conference on Earthqu3ke Engineering, Santiago, Chile, 1969 Sho.W. Nuttli, Design Earthquakes for the Central United States, U.S. Army Engineer Waterways Experiment Station fliscellaneous Paper S-73-1, 1973 mJ.B. !!adley, and J.F. Devine, Seismotectonic Map of the 14 Eastern United States, U.S. Geologic Survey, publication !IF-620, 1974
( *S.T. Algermissen, and D.1. Perkins, A Probabilistic Estimate -
\ of flaximum Acceleration in Rock in the Contiguous United States U.S. Geologic Survey, Open File Report 76-416, 1976 NN.C. Donovan , B. A. Bolt, and R.V. Whitman " Development of Expectancy !!aps and Risk Analysis," American Society of Civil Engineers annual convention, Philadelphia, Preprint 2805, 1976 UGDocekal, Earthquakes of the Stable Interior, with Emphasis on the !!idcontinent (Vol 1 and 2), University of Nebraska, PhD
' thesis University Microfilms, 1970 UUU.S. Department of Commerce, U.S. Earthquakes 1938, 1940
- 02) U . S . Department of Commerce, U.S. Earthquakes 1944, 1946 A.J. Eardley, Structural Geology of North America, Second Edition liarper Row, 1962 I
l
'- Revision 14 Q&R 2.5-15 10/78
Responses to NRC Questions Midland 1&2 i Question 361.7 (2.5)
You have not responded fully to Question 361.5. Provide a comparative quantitative analysis of the seismicity within 200 miles of the site and other similar sized areas in the Central Stable Region. The purpose of this analysis is to permit 18 i a more detailed evaluation of your contention that the Michigan l Basin should be considered separate from the Central Stable Region.
Response
As stated in the response to Question 361.5, it is our opinion that the Michigan Basin is an area that, for the purpose of evaluating the safe shutdown earthquake at the Midland site in the context of 10 CFR 100 Appendix A and Regulatory Guide 1.70, is sufficiently distinctive.in both its geologic and seismic characteristics to justify its acceptance as a convenient and realistic tectonic or seismotectonic province separate from the Central Stable Region as a whole. The historical seismicity is certainly consistent with subdividing the Central Stable Region
~
into smaller tectonic provinces. Several zones of clearly distinguishable, relatively high seismic activity occur within the Central stable Region in terms of both numbers of events and, size of the maximum historical event. However, no such zones occur within the Michigan Basin tectonic province. It has h~ experiencea only a few scattered small events in historic time, and none have had an intensity greater than VI. (The Modified 24 Mercalli Intensity Scale has been used to measure the intensities of seismic events referred to throughout this response. )
To quantify these observations, a statistical test has been performed using earthquake activity rates in several subareas of the Central Stable Region. In this analysis, the Michigan Basin is compared to similar size subareas within the Central Stable Region. In this context, the Central Stable Region of the eastern United States is as outlined and described by King.*
This region is shown in Q&R Figure 2.5-3. Although other slightly different characterizations of the precise boundaries of the Central Stable Region exist, n .m the outline shown in Q&R Figure 2.5-3 is conservative for the purposes of this analysis.
All historic earthquakes within this region of intensity greater than or equal to V were tabulated. The principal data sources used in this tabulation were Coffman and von Hake,* Docekal,*
and Nuttli.* The total data set thus derived, after all obvious aftershocks are removed, consists of 174 earthquakes, with the earliest noted event occurring in 1776. Because the earthquake detection and recording process has - t been uniform during the approximate 200 year interval from ths first recorded event to the present (as may be readily seen by plotting a histogram of the number of events per decade for this data set), an Revision 24 Q&R 2.5-25 gj79
_ _ _ . _ _ r
Responnon to NRC Questions Midland 1&2 alternative and more uniform subset was also considered. This (
nubset contains the 141 earthquakes of the original data set that occurred after 1900.
A total of five nonoverlapping subareas within the Central Stable Rcgion were selected for initial analysis. These are shown in Q&R Figure 2.5-3. Subarea A'of this group is the 100,000 square mile Michigan Basin as shown in FSAR Figure 2.5-6. Subareas B through E are approximately 180 mile radius circles centered near Middleport, Ohio; Springfield, Illinois; Omaha, Nebraska; and Cherokee, Oklahoma. The subarea centered near Middleport, Ohio, was selected to include the cluster of historic activity in the Anna, Ohio _ area, while Subarea C, centered near Springfield, Illinois, was. chosen to encompass the large historic earthquake ssquence north of the Mississippi embayment. Subareas D and E ware selected with no particular attempt to include or exclude pockets of seismic events.
For the complete earthquake data set, 4, 25, 42, 13, and 19 carthquakes of intensities greater than or equal to V occur in Subareas A through E, respectively. For the truncated, post-1900 data set, the equivalent numbers are 2, 21, 32, 8, and 19.
24 The statistical test performed using these subarea earthquake activity rates is as follows: If,the Central Stable Region is assumed to be homogeneous in terms of its seismic characteristics, and if the historic earthquake record affords a f' reasonable estimate of the earthquake recurrence properties of the region as a whole, what are the probabilities of observing the above numbers of earthquakes in each subarea for the time intervals of the two data sets?
Assume, as is generally done, that earthquakes occur as Poisson arrivals. The Poisson process has been found to adequately describe the occurrence of large events when aftershocks are disregarded, and the assumption of this process has been used in previous analyses of eastern United States earthquakes.m Under this assumption, the probability of observing "n" earthquakes in "r" years given an activity rate "v" is:
P (n in r/g ) =e -rf (vr )n n!
Under the conditions of the statistical test proposed above, a I reasonable estimate of the activity rate is provided by the historical earthquake data. Considering first the complete data set, F = 174 events /200 years /1,300,000 square miles !
( ,
Q&R 2.5-26 e{fsion24 I
. : : , . .- :- T:: - - . .. .
l l
1 Responses to NRC Questions Midland 1&2 where the area shown is that of the Central Stable Region. For a subarea of 100,000 square miles, the equivalent activity rate '~
becomes:
u subare/: 13.38 events /200 years /100,000- square miles Thus,for any subarea with' data collection over a 200 year period, vr=13.38. For a Poisson distribution, this value is both the mean and vari nce. Therefore, the first integer numbers of errthquakes to fall outside the mean +1 standard deviation range
- a. 9 on the. low side and 18 on the high side of the mean.
Numbers for events outside the mean +2 standard deviations are 6 on the low side and 21 on the high side of the mean.
Performing a similar analysis in the case of the truncated data set, ,
v s bara;10.85 events /76 years /100,000 square miles With data collected over a 76 year period, e r =10.85. Th integer 24 numbers of earthquakes falling outside the mean +1 and +2 C standard deviations in this case are 7 and 15, and 4 and 18, respectively.
The integer ranges may be compared to the observed number of earthquakes in the various subareas. For the complete data set, only Subarea D falls within the mean +1 standard deviation limits, and Subareas D and E fall Within the mean +2 standard deviation limits. For the truncated data set, only Subarea D falls within either the mean +1 or mean +2 standard deviation limits.
The Micnigan Basin contains far fewer events and the subarea including the Anna, Ohio, activity contains far more events than would be expected from random fluctuation of a statistically homogeneous process under both data set calculations. In particular, the probability of four or less earthquakes occurring within the Michigan Basin in a 200 year period under the assumption of the above analysis is just under 0.003, while the similar probability of two or less events in a 76 year period using post-1900 data only is 0.0014.
It is our opinion that this analysis supports our previous conclusion that historic earthquake data is consistent with subdivision of the Central-Stable Region into smaller tectonic provinces. Along with a number of previous and independent studies, (s.9 . 1 c. it. 12.138 it shows that significant differences Revision 24 Q&R 2.5-27 9/79 1
l l
Rocponssa to NRC Questions Midland 1&2 in seismic hazards within the Central Stable Region exist, and that the area around the Midland site is among the areas within the Central Stable Region characterized by the lowest hetard 1svels.
Although the separation of Subarea B (containing the Anna, Ohio, activity) and the Michigan Basin is already clearly implied by the above analysis, a more direct consideration of the historical seismicity of the Central Stable Region suggests even more strongly that the area immediately around Anna, Ohio, should be separated both from the Central Stable Region as a whole, and from the Michigan Basin in particular, for the purposes of specifying proper seismic design parameters applicable in the naar future. This has been done in all the studies referenced in i the previous paragraph. )
Consider, for example, the recent characterization of the Anna, Ohio, seismic source zone appearing in Nuttli and Herrman.M 33 With the geography of this source zone so characterized, it has an area of about 14,000 square miles and has been the site of 12 enrthquakes since 1875 with intensities of V or more. Four of l these events were of epicentral intensity VII, and one was an l cpicentral intensity of VII to VIII. Body-wave magnitudes of 5.3 are assigned to these five earthquakes in the Nuttli and Herrmann 24 l study."3) l I
A very distinctive feature of the Anna, Ohio, source zone i seismicity is this preponderance earthquakes that have intensities of VII or greater. Of the 20 earthquakes in this intensity range within the Central Stable Region, five have occurred very near Anna, Ohio. This represents 1/4 of the ecrthquakes in this intensity range within approximately 1/90 of the total area. This source zone is also distinctive because 12 Odrthquakes with intensities of V or greater have occurred in this zone. Under the assumptions of the probability analysis above, the random occurrence of 12 or more events in such a small area is over seven standard deviations from the expected number of approximately two. This concentration of earthquake activity is equalled within the Central Stable Region, as shown in Q&R Figure 2.5-3, only in the Ozark uplift and Wabash Valley outliers i of the New Madrid seismic zone.
In these ways (occurrence of large events which have an intensity of V or greater, additional relative concentration of events which have an intensity of VII or greater), the area around Anna, Ohio, is in marked contrast to the Central Stable Region as a whole and in striking contrast to the Michigan Basin.
When this data on historical seismicity is considered along with the facts that the Michigan Basin is geologically distinguishable from the remainder of the Central Stable Region and that the Michigan Basin is characterized by a consistency of the structural features within it, it is our opinion that this is an N
Revision 24 Q&R 2.5-28 gj79
Responsos to NRC Questions Midland 1&2
,' adequate basi or considering the Michigan Bhsin to be a tectonic provin :e as defined in 10 CFR 100 Appendix A.
UlP.B. King, The Tectonics of Middle North America, Princeton University Press, Princeton, New Jersey, 1951
- A.J. Eardley, Structural Geology of North America, Harper & Brothers, New York, 1951
- P.B. King, The Evolution of North America, Princeton University Press, Princeton, New Jersey, 1959 WJ.L. Coffman and C.A. von Hake, (ed), Earthquake History of the United. States, Publication 41-1, Revised Edition, U.S. Department of Commerce, 1973
- J. Docekal, Earthquakes of the Stable Interior, With Emphasis on the Midcontinent, University of Nebraska 24
,Ph.D.
( Thesis), 1970 0.W. Nuttli, Magnitude Recurrence Relation for Central
( Mis,issippi Valley Earthquakes, Bull. Seismo.
Soc. Am. 64, 1974
- R.K. McGuire, Effects of Uncertainty in Seismicity on Estimates of Seismic Hazard for the East Coast of the United States, Bull. 7eismo. Soc. Am. 67, 1977
- S.T. Algermissen, Seismic Risk Studies in the United States Proceedings of the Fourth Fork Conference on Earthquake Engineering, Santiago, Chile, 1969
- O.W. Nuttli, Design Earthquakes for the Central United States, Miscellaneous Paper S-73-1, Report 1 (1973),
U.S. Army Engineer Waterways Experiment Station "M J.B. Hadley and J.F. Devine, Seismotectonic Map of the Eastern United States, Publication MF-620 (1974),
U.S. Geological Survey "U S.T. Algermissen and D.M. Perkins, A' Probabilistic Estimate of Maximum Acceleration in Rock in the Contiguous United
~
States, Open File Report 76-416 (1976), U.S. Geological Survey 0 21 N.C. Donovan, B.A. Bolt, and R.V. Whitman, Development of Expectancy Maps and Risk Analysis, Preprint 2805 (1976),
(
Revision 24 Q&R 2.5-29 9/79 i
I
l Responses to NRC Questions Midland,1&2 American Society of Civil' Engineers Annual Convention, -
- Philadelphia, Pennsylvania !
(*0.W. Ni tli and R.B. Hermann, Credible Earthtfuakes for the 24 Central United States, Miscellaneous Paper S-?3-1,
, Report 12-(1978), U.S. Army Engineer Waterways Experiment Station t
Y Revision 24 Q&R 2.5-30 9/79
. . . . . _ , _ . . . . _ . . _ _ _ . . . _ . . _ _ . . _ . . _ . _ _ .._ . . , _ _ u- _ _-_ _. _ . _ . .
Attachment 7 !
Responses to NRC Qucations Midland 1&2 ,
1 Question 362.9 .(2.5.4) ( l The responne' to Request 362.4 is insufficient. Table 2.5-14A shows the structural settlement measurements available to date. 14 Provide the reasons for the lack of survey data at Benchmark Numbers A-3 and 4; C-2, 3, 4, 5, 6, and 7; and T-2, 5, 6, 7, 8, 9,_ 10, 11, 12, 13, 14, and 15. In Subsection 2.5.4.13.1 of the l
FSAR, reference is made to Figure 2.5-78. The figure number is in error and should be corrected. i 1
Rnsponse Table 2.5-14A has been revised to include the settlement msasurements for the subject benchmark numbers. .
Subsection 2.5.4.13.1 has been revised to reference the correct figure.
Scttlement benchmarks have been installed and monitored at selected locations on the major plant structures. Benchmark locations are shown in Figure 2.5-48A. Benchmark elevation 18 mnasurements are presented in Table 2.5-14A.
Maasured settlements were not measured from the start of construction. 'Available settlement measurements are presented . ,
graphically in Figures.2.5-89 through 2.5-91 for the reactor, (_
cuxiliary, and turbine buildings. Building load intensities catimated from actual material quantities used in construction are also shown in Figures 2.5-89 through 2.5-91.
Subsurface conditions for various Seismic Category I structures on fill are under investigation. The maximum predicted 20 ssttlements will be recomputed based on this investigation. A comparison of the observed settlement and the maximum predicted settlement will be provided by amendment in January 1980. 124 s
Q&R 2.5-16 Revision 24 9/79
. ~ _ . . . . . ., _ . . . , , - _
- A-1 l
l AUXILIARY BUILDING I 1
C1 C4 C5 C2 lT I i CONTAINMENT A-6 b' T 15 e A5 A 4; e
i l
TURBINE BUILDING T-8 T3 - *T 6 *' -
l 1
+
T-2 - -
- T-5
- T7 l
T-1 .T 4 l
j 1
A2 NOTE A 1 MONITORING SETTLEMENT BENCH MARK LOCATION j C-8 l
\
j J
UNIT II ~
CONTAINMENT O h
f v
Cy A-3 g T-14
+ _ T 12
, CONSUMERS POWER COMP.
. _ T-11 MIDLAND PLANT UNITS I ,
T9 FINAL SAFETY ANALYSIS RE O Settlement Bench Mark Locatic the Power Block (SK-G-209)
{ FSAR Figure 2.5-48A 10/78 Revi l
l
1
. .- i 1
'Roeponses to NRC Questions I Midland 1&2 Attachment 8 Question 362.9 (2.5.4) (
The response to Request 362.4 is insufficient. Table 2.5-14A shows the-structural settlement measurements available to date. '
l Provide the reasons for the lack of survey data at Benchmark 14 Numbers A-3 and 4; C-2, 3, 4, 5, 6, and 7; and T-2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, and 15. In Subsection 2.5.4.13.1 of the FSAR, reference is made to Figure 2.5-78. The figure number is .
in error and should be corrected. I
Response
Table 2.5-14A has been revised to include the settlement measurements for the subject benchmark numbers.
Subsection 2.5.4.13.1 has been revised to reference the correct figure.
Settlement benchmarks have been installed and monitored at selected locations on the major plant structures. Benchmark locations are shown in Figure 2.5-48A. Benchnark elevation 18 measurements are presented in Table 2.5-14A.
Measured settlements were not measured from the start of construction. Available settlement measurements are presented
. graphically in Figures 2.5-89 through 2.5-91 for the reactor, e auxiliary, and turbine buildings. Building load intensities (~
estimated from actual material quantities used in construction are also shown in Figures'2.5-89 through 2.5-91.
Subsurface conditions for various Seismic Category I structures on fill are under investigation. The maximum predicted settlements will be recomputed based on this investigation. A 20 comparison of the observed settlement and the maximum predicted settlenent will be provided by amendment. 126 I
l l
l\
Revision 26 - r Q&R 2.5-16 1/80 l
L _
.x / .
\. V
.[ kg UNITED STATES Attachment 9 D j NUCLEAR REGULATORY COMMISSION
- WASHINGTON, D. C. 20656
...../ MAR 311980 Docket Nos.: 50-329/330 APPLICANT:
Consumers Power Company FACILITY:
4 _ Midland Plant, Units 1 & 2
SUBJECT:
SUMMARY
OF FEBRUARY 27 & 28, 1980 ,
CONSULTANTS TO REVIEW S0IL SETTLEMENTMEETING AN On February 27 and 28,1980, the NRC staff and three organizations recently matters, met with Consumers Power Company (t Bechtel consultants at the site for Midland Plant, Units 1 & 2 g
The three Energy Technology Engineering Center, and U.
neers, Theeffects.
and purpose of the visit was to review and observe ons Center. site backfill d c encies meeting was documentation matter.
held to assist these consultants with on the backgr,ound, remedial work and present stat -
Meeting attendees are listed in Enclosure 1. us of this Midland FSAR, DecemberThe 19, 1979, information reviewed at this meetin o the e
in two voluw s by the applicant's letter of February 11for orwarded
,1980. One of the which reference Generator Foundations and Building," consists o sentNovember from by the applicant to theSeptember 7,1978 through staff's Office of Inspection 5,1979.
and Enforceme reports 10 CFRthrough April 24,1979 50.54(f) responses to the Office November 13, 1979.
p cant's of Nucle submitted These documents represent the
-applicant's modification of the r'eports upon construction which permits is based. the staff's order of December responses in the latter volume intended for submitta February, 1980.
requests of November Revision 19, 1979.5 will Onlyinclude informat responses to the staff's supplemental documents is included in this' meeting summary. ion not contained in these ;
' In opening remarks, Mr. G. Keeley announced thatpany Consumers has Power elected to defer all remedial work on inadequately supported stru acceptance of the proposed work' is received from the staff.
This action'is l
l t
%# of gooWlOO W .
i
_ . . _ . . . . . . . . _ . _ . . - --~
4 o .
( { .'
, MAR 311980 A
voluntary on the applicant's part since the effective date for the staff's December 6,1979 order is to be established by the Hearing Board pursuant to 10 CFR 2.204. .The basis for this decision was said to be to preclude potential been of.
loss revenue associated with expenditures for which staff approval has not granted. '
The staff observed that this was a prudent decision, particularly in view of the significant slip in construction completion projected by Bechtel andTMI-2 the currently under review by the applicant and due to other causes, principally acc-ident.
presentations were also given by Bechtel consultants. Mr s C. H. Gould dascribed the procedure for placement of caissons beneath the electrical penetration area (i.e., wing: walls) of the Auxiliary Building and beneath the Feedwater Isolation Valve Pit area. Mr. M. T. Davisson described the procedure for placement of piles to support the northern portion of the Service Water Building. Dr. A. J.
' Hendron,-Jr. , reviewed the preloading program completed for the Diesel-Generator Building and discussed why the preload option was elected in lieu of other
. possible corrective alternatives.
Dr. R. B. Peck sumarized the recomendations of the Bechtel consultants and emphasized that the preloading option is con-sidered to eliminate the need for any further testing or measurements as a basis for establishing confidence for future settlement potential of the Diesel Generator Building. A summary of these discussions by the Bechtel consultants will' be submitted as an amendment to. the FSAR, During the meeting, references were made to certain information and reports which have not been made available to the NRR staff, although some of these have been examined by I&E through the audit mechanism. Examples include:
1.
Some of the figures listed in the drawing sumary for the interim reports to MCAR #24 which are not included with the compilation of reports forwarded by the applicant's letter of February 11, 1980, replacements and redundancy are taken into account.even after noted figure 2.
Installation details of each piezometer used to monitor pore water pressures during the preload program (e.g., type and actual elevations of installed piezometers, backfill mater'ials and zone thickness).
3.
l Report's, meeting sumaries, or other written communications with or by consultants recomending or supporting remedial measures for structures and utilities located upon or in questionable soils.
, 4.
Reports of the evaluation (e.g., bases, procedure, execution and results)of the initial qualification and subsequent requalification of compaction eqaip-ment, ,
I l 5.
- The report " Tank Fann Investigation; Midland Units 1 & 2," issued October, 1979.
6
. i
.l '
~
d
( (I
'/ .
MAR 31 ISSO The staff noted that such documents as above are needed by its consultants for their independent assessment of the adequacy of the and requested that these be made publicly available. proposed remedial indicated The applicant measures ;
a reluctance to this end, and noted that these were available through the I&E audit mechanism. l The staff will issue a formal request for these documents. The staff also noted that the boring logs provided in Appendix'2A of the FSAR did i not reflect replied thatthose these borings would beassociated added. with piezometer installation; the applicant i i
Site tours were f.rovided in groups based upon the following engineering disciplines: '
(1) Geotechnica's, (2) Structural, (3) Mechanical, and (4) Hydrologic.
l During the tour the Corps noted that except for the use of temporary blocks, the service wecer pipe would otherwise be in direct contact with the base of the penetration through the northern wall of the Service Water Building. It is postulated that this results from the more rapid settlement of the buried pipe ,
relative to the building's cantilevered settlement. The Corps emphasized that i special attention should be given this area to avoid stressing the pipe at the penetration, particularly during pile driving and after attachment of the piles to the structure.
The staff noted that the presentation by Mr. C. H. Gould included the specification of some quantitative Auxiliary Building. criteria to be applied during the remedial action for the
~
The staff asked if similar criteria were specified by the '
other Bechtel consultants, but was advised that these other criteria were more of a qualitative, subjective nature. ,
The staff also requested the applicant to submit a description of the services to be performed by consultants R. B. Peck, A. J. Hendron, Jr. , C. H. Gould and M. T. Davisson through the completion of construction on the remaining remedial fixes. - This description should identify the extent of continued involvement of the consultants in overseeing construction operations and in evaluating the effectiveness of completed fixes for which they have provided major design input.
2 ((c t ' I Darl S. Hood, Project Manager Light Water Reactors Branch No. 4 Division of Project Management
Enclosures:
- l. Attendees
- 2. Agenda',, .
j cc w/ enclosures: 1 See next page.- -
i
~
/
- .,e..'.'
(
((tI ENCLOSURE 1 .
ATTENDEES Consumers Power Bechtel Consultants G. S. Keeley Harris Burke T. C. Cooke R. B. Peck Sherif Afifi A. J. Hendron, Jr.
,T. Thiruvengadam Don Riat .
C. H. Could U. E. Horn Bimal Dhar M. T. Davisson Bill Paris J'slius Rote '
Jim Wanzeck Karl Wiedner John Rutgers Lynn Curtis
. . Al Boos Chuck McConnel '
Walter Ferris NRC US Corp Of Engineers ETEC L. Heller N. Gehring W. P. Chen J. Grundstrom ,
J. Kine . J. Bramer - '
A. Cappucci W. Otto W. Lawhead F. Rinaldi P. Hadala ,
R. Gonzalis J. Simpson f
D. Hood G. Callagher J. Norton I 1
R. Cook R. Erickson !
l US Navy Weapons Center h ,
P. Huang .,
, i J. Hatra
'f.
n l
a@* c 1 l
l
. , - iI
-~ ~
. .:A ! ...*
I j 4 4 ..
7s g ..5 ~
- . ,r
'E
$~@,r, . f ,,,1
. h ,'?
7 ,'
.t w SlN'
- s: t,'
E.Mt $,, D,f hig.;.y#Q...'. "I~
g
- ' ./. ' ,? ENCLOSURE 2
(
_ . . . . AGENDA.FOR._.
MEETING WITH NRC ON MIDLAND PLANT FILL STATUS AND RESOLUTION February 27 & 28, 1980 l Midland Site .
1
~~ ~ ^ i
1.0 INTRODUCTION
C. Keeley 2.0 PRESENT STATUS OF SITE INVESTICATIONS T. Cooke 2.1 Meetings with consultants and Options Discussed (Historical) 2.2 Investigative Program A'. ~ Boring' Program *
.B. Test Pits .
. ..C. Crack Monitoring and Strain Gauges'* .
D.,,, Utilities [., .. .. , , , ,
~' '
2.3 Settlement
]
A. Area Noted . '
B. Preload 1
,. . C .' Instrumentation ..
. i
. i l
" 3.0 WORK ACTIVIIY UPDATE J. Wanzeck
- 2. . s
- Mi'
3.1 Summary of work activities and settlement surveys for all Category I structures and facilirties founded part.ially or 0 , totally on fill. .'
's-J
~ f t.5 ~ .
' ,; - 4.0 REMEDIAL WORK IN PROGRESS OR PLANNED (Q4, 12, 27, 31, 33 & 35) S. Afiti
~&.'r 7 4.1 Diesel Generator Structures ... ,
.%,3 h,i 4.2 Service Water Pump Structures ,
i 4.3 Tank Farm >F,fi d-
]rj 4.4 Diesel Oil' Tanks .
, ,-< ,9fi'
- i 4.5 Underground Facilities - /
4 4.6 Auy.iliary Building and,FW Isolation Vtive Pits . 4, .
..;* 4.7 Liquefaction Potential- '
p .
' W .-
l
.5.0 EVALUATION OF PIPING (Q16,'17,'18, 19 & 20) 3 D. Riat'.' '
i n.
6.0 DEWATERINO (Q24) -
B. Parie 7.0 ANALYTICAL INVESTIGATION , T ll B. Dhar$4 [ l w,
a 7.1 Structural Investigation (Q14, 26, 28, 29,30 & 34) t ;
' 7.2 Seismic Analysis (Q25) MQ > l ci* f I !
,/; 7/,p 7.3 Structural Adequacyjwith Respect to PSAR, FSAR, etc. '
.w . , ; - ' g* [4
, g8. 0 SITE TOUR,'.m y-- -
- 4. -.
All ',g;, . **'
' l f ..
9.0 CONSULTANTS SD9fARY .-
' Peek'/He
, o;:n. 3: ' -
e' ,c ? Could/ .
,. , "yf
. .- ? .
10.O DISCUSSION
,by ;. . .'r, A11*' ' )
y *
.s !
- .W
- ' ,.y ,p?. .
3 f,, -
< J , ,c . y , . gs. . , .
.' j'k(
4 iT.-lj Wt4. '
f.,. , , t C , ' I q . [,f j ';. > .,j l' . c. ^NhSh;MW [ $
. = . . - - -
o
- [
- 5 ' * %^?t0y
/' gh UNITED STATES "
[' g. NUCLEAR REGULATORY COMMISSION 5 ej' WASHINGTON. D. C. 20555 A.,.....j .
I '
APR 1 1980 .
Docket Nos.:: 50-329/330 .
Mr.'S. H. Howell
.:Vice President Consumers Power Company 212 We:t Michigan Avenue
! Jackson, Michigan 49201
Dear Mr. Howell:
SUBJECT:
REQUEST FOR REPORTS, ORAWINGS AND OTHER INFORMATION REGARDING PLANT FILL SETTLEMENT AND EFFECTS As indicated in previous correspondence and our meeting with your staff on *
- February 27 and 28,1980, the NRC staff reviews of the-adequacy of the backfill soils,' settlement effects and associated remedial actions are proceeding with the support of three outside organizations or agencies: the U. S. Army Corps of Engineers, Engineering the U. S. Naval Surface Weapons Center, and the Energy Technology Center.
In order that they may perform the independent assessments drawings an these matters. requested, we and they require detailed reports and of these areas as we have Drawings Our review of the " Drawing Summary" in Management Corrective Action Request 24 indicates that several of the 91 drawings listed in Interim Report 8 are not included with the compilation of reports forwarded b of February 11, 1980 as the volume entitled "10 CFR 50.55(e)y your letter
, Interim Reports, Settlement of Diesel Generator Foundations and Building." Some of the drawings listed in the summary are noted to be replaced by other drawings, and overlaps in drawings occur with the successive updating of
' the list from one interim report to the next. Notwithstanding this re-placement and overlap, some drawings are not provided. We request that ,
you amend this volume to include all missing drawings and to provide an !
J index table specifying the location of each drawing.
Reports We request that you provide 40 copies of all reports, including meeting swmaries and other written communications, with or by consultants who i have performed investigations or tests or made recommendations regarding the supporting soils.or remedial measures for structures and utilities I located on or in questionable materials. An example of the reports needed is provided by Enclosure I which lists a few of the reports by Bechtel and
- l
(
h?6 % o04WOI
~
~
f Mr. S. H. Howell APR
[ .
1 1980 by Bechtel's consultant, Goldberg-Zonino-0unnicliff.
intended to be complete nor to identify all consultants involved.
The list is not it is intended to illustrate the level of technical detail needed. Rather, We request that you include our consultants for direct receipt of a set of these documents.
Other Information We require information detailing the installation of each piezameter used to monitor pore water pressures during the surcharging program. This should include the type and actual elevations of the installed piezometers, the types of backfill material placed and their extent in the drilled hole. M We also require a description of the services to be performed by con-sultants R. 8. Peck, A. J. Hendron, Jr., C. H. Gould and M. T. Davison. .
This description should identify the extent of the continued involvement i of these consultants in overseeing the remedial construction operations and in evaluating the success of the completed fixes intended to provide stable foundations for the various structures.
We would appreciate receipt of the above documents, drawings and information within 20 days of receipt of this letter. Please advise us within 7 days if you will meet this schdule so that we may adjust our review schedules accordingly.
Sincerely, .
>c' -
d .5~ 9 ...... k ..-
L. S. Rubenstein, Acting Chief Light Water Reactors Branch No. 4 Division of Project Management
Enclosure:
List of Reports cc w/ enclosure:
See next page.
l
' ~
Consumers Power Company ccs:-
Michael I. Miller , Esq.
! sham, Lincoln & Beale
(-'
Sui tt.: 4200 One First Nation 4) Plaza Chicago. Illinois 60603 Judd L. Bacon, Esq.
Managing Attorney Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr . Paul A. Perry Secretary -
Consumer s Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 Myr on M. Cherry, Esq.
One IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 f Frank J. Kelley, Esq.
Attorney General
( State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Mr. Wendell Marshall
,. Route 10 Midland, Michigan 48640
, Grant J. Merritt, Esq.
Thompson, Nielsen, Klaverkamp & James 4444 105 Center 80 South Eighth Street Minneapolis, Minnesota 55402 Mr. Don van Farowe, Chief Division of Radiological Health l,< Department of Public Health P. 0..80x 33035 Lansing, Michigan 48909 m.
gggj Consumer s Power Company ces (centinued):
f2 Residint inspector / Midland NPS c/o U.S. Nuclear Regulatory Commission i P. O. Box 1927 Midland, Michigan 48640 )
William J. Scanlon, Esq. i 2034 Pauline Boulevard Ann Arbor, Michigan 48103 i
Commander , Naval Surface Weapons Center ATTN: P. C. Huang ,
. G-402 White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering
- Energy Technology Engineering Center P. O. Box 1449 Canoga Park, California 91304
'. Mr. William Lawhead U. S. Corps of Engineers
/. NCEED - T 477 Michigan Avenue -
7th Floor
(/ Detroit, Michigan 48226 t
O 0
4 e au
.. / .
1
. .- ENCLOSURE 1 i 1
2 ' Sample Listing of Reports Needed by Staff's Consultants
(#
I. Reports Prepared by Goldberg-Zonino-Dunnicliff
- 1. Report entitled " Test Pits 1, 2 & 3," dated Feb.1980 File No. 2190 (Index C-79(Q)-20)
- 2. Report " Data Suninary and Laboratory Procedures," dated Feb.1980 (IndexC-79(Q)-16)
- 3. Report " Consolidation Tests," dated Feb.1980 (IndexC-79Q-17)
- 4. Report -Strength Tests," dated Feb.1980 (IndexC-79Q-18)
- 5. Report " Miscellaneous Tests " dated Feb.1980 (IndexC-79Q-19) 1
- 6. " Soil Classification and Moisture Density Relation" dated Feb.1980 l (IndexC-79(Q)-21)
- 7. " Diesel Generator Building Instrumentation," dated October 1979 (Index C-82(Q)-5)
/ 8. "Aquaducer Hose Settlement Gage Instrumentation Manual" ~
( (IndexC-79(Q)-4)
- 9. " Report on Sondex Gages ard Borros Anchors" (IndexC-82(Q)-8)
- 10. " Report on Sondex Gages and Borros Anchors" (IndexC-82(Q)-9)
.- 11. " Procedure for Reading Sondex System" 1 (Index C-82(Q)-2) l
- 12. " Procedure for Reading Modified Borros Anchors" 1 (Index C-82(Q)-3) )
II. Bechtel Reports
- 13. " Test Pit 1 Data," dated Sept.1979 (Index C-79(Q)-10)
{
- 14. " Test Pit 2 Data," dated Sept. 1979 (Index C-79(Q)-il) j
. 15. " Test Pit 3 Data," dated Sept.1979 (Index C-79(Q)-12)
- 16. " Test Pit 4 Data," dated Sept.1979 (Index C-79(Q)-13)
, 17. " Plate Load Test PL-1," dated Sept.1979 (Index C-79(Q)-14) k
- 18. " Plate Load Test PL-2," dated Sept.1979 (Index C-79(Q)-15)
$u$
v ,~, ---
n.>. . . .
hhh$,#
5
( 19. " Qualification of Compaction Equipment" 20 " Tank atin Investigation" o
l l
i i
1 4
1
(.
e I
1 l
- . 1 I
i l l
l i
!(
l e4
-', r
( G., m.
Attachment 11 UNITED STATES .
j' y NUCLEAR REGULATORY COMMISSION
'f WASHINGTON, D. C. 20666 e g j JAN 121979
\ . . . . . ,p!
~
\
DOCIETNOS. 50-329 4 50-330 APPLICANT: Consumers Power Company FACILITY: Midland Plant, Units 1 & 2 .
SUBJECT:
SUMMARY
OF DECEMBER 4,1978 MEETING ON, STRUCTURAL SETTLEMENTS On December 4, 1978, the NRC staff met in Midland, Michigan with
- Consumers Power Company (CPCO), Bechtel Associates, and consultants in geotechnical: engineering to discuss excessive settlement of the Diesel Generator (DG) Building and pedestals, and settlement.of other seismic Category I structures. These technical discussions followed a site tour on 0ecember 3,1978 during which the NRC staff observed
~
~
each of these structures. Attendees for the tour and technical dis-
- cussions are listed in Enclosure'1. Enclosure 2 is the agenda used during the technical discussion.,
- 1. Background -
Pursuant to 10 CFR 50.55(e), CPCO notified Region III of the Office of Inspection and Enforcement (I&E) on September 7,1978,
/j that settlement of the Midland DG Building foundation and generator pedestals was greater than expected and that a soils boring program had been started to determine the cause and extent of' the problem. An interim status report was provided I&E by CPCO's letter of September 29, 1978. I&E conducted inspections on this matter on October 24-27,1978 and issued inspection report number 50-329/78-12; 50-330/78-12.
,2. History The Bechtel representative identified the Category I structures and the type of material supporting the structure:
- a. Containment - Glacial Till
- b. Borate,d Water Storage Tank - Plant Fill
(, c. Diesel. Generator Building and Pedestal - Plant Fill
.' . . d . Auxiliyy Building - Part Glacial Till & Part Plant Fill g
- 4
- e. Service Water Intake - Glacial Till (Compieted portion only)
I
- Plant Fill (Small portion yet to be constructedi SC W 190t35095,2
-- { - . . . . .
{}
N
'J JAN 121979
( '
i I
kthemeasuredsettlementsareasfollows:The settlement monitoring
- p Containment - 1/4" to 5/8." over last 1-1/2 years Auxiliary Building - Approximately 1/8" (central portion)
Service Water Pump House - O to 1/8" Diesel Generator Building - 3 to 4" since footing was poured October 1977 and walls in Spring 1978, The four electrical duct banks rising into the DG Building, and which extend downward into the glacial till, were cut loose to remove the settlement restriction on the north side of the DG Building. When the duct banks were cut loose, settlement on the order of 2" occurred on the north side of the DG Building at a rapid rate. The east wall exhibited rapid settlement (1/8" in one week), but the west wall showed very little subsequent settle-ment. This indicates that the east wall was being held up by the duct pedestal.- .
- 3. Soils Exploration
\
- Bechtel discussed the soil exploration program, including the
/ boring program and laboratory testing of the foundation materials.
- The conclusion that was made by Bechtel is that the material varies across the site in strength properties,'i.e., unconfined compressive
.+
- strength from 200 PSF to 4000 PSF and shear strength from 100 PSF to 2000 PSF. The soils classification ranged from C1 to M1.
Bechtel also discussed possible causes based on input from a con-sultant, Dr. R. Peck. Some of these causes were:
(1) variable quality of material used in the plant fill, however, the quality control records do not indicate the variation.
- (2) Fill may have been placed on the dry side of optimum moisture, {
- and then when the water table rose inundating the fill, the l material may have become " soft."
} -
' g (3) Initial fill may have been placed satisfactorily but after
- installing pipe trenches and duct banks, the fill may have been disturbed.
4- .
t i 1 . .
a e I.s
g
-3 JAN 121979 J
g' , .4. Consultants Perspective br.R.B.Peckstatedthefollowing:
t
). The compacted fill is comprised mainly of glacial till and I was excavated from the cooling pond area.
b.
Evidence exists from the Dutch cone curve that the looser and softer areas are limited to local zones or lenses.
c.
Water content is higher than at the time the fill was placed.
Settlement of the till has been occurring since original placement of fill, accelerated by increased moisture content resulting from filling of the discharge cooling pond. Soil settlement is occurring under its own weight and the added weight of the building is believed to be insignificant.
d.
The DG Building would probably not have settled as much if the material had not been so wet (moisture content is high).
a.
Bearing capacity is not a problem for the footings.
f.
Short of removing all the fill above the hard glacial till, a "preload" program would be the best approach. The preload purpose would be to consolidate the fill. materials. ,
g.
The settlement with the preload would tend to be rapid (a fewweekstoafewmonths),
/
h.
The preload is a necessary first step even though other measures might be necessary.
~
- 1. The main unknown is what might happen to the rate of settlement as the water table rises and saturates the fill,
- j. Preloading would. occur in early 1979 and the sand used as the surcharge would be removed in mid-1979, Mr. C. J. Dunnicliff of Goldberg, Zoino, Dunnicliff & Associates
- described the instrumentation program to monitor the settlement c.f_the foundation material and structures during the preload,
- The purpose of the instrumentation is to determine if the surcharge is doing its job of consolidation and if it is causing any harm
_.to the structurps or utility lines under and around the building,
- i. Le 2 :- . , . + .
,8 ,:
E a j ': '- .
4 .
4 '
g l
G m'
.. g Y, '
/
JAN 121979 4 .
.. . f-a.,g Instrumentation for the structure will include optical survey i measurements as well as monitoring of cracks using electrical ,
devices. Four locations for the electrical devices have been chosen; two .on the exterior of the east wall of the DG Suilding and two on the west wall of bay number four in the OG Building.
A mapping of cracks will be developed,
- b. Foundationmonitoringwiliincludedevicestomeasuresettlement and pore water pressure. A total of 60 anchors will be installed (20 groups of 3 at different elevations). A total of 40 piezomete:s are to be installed to measure the pore water pressure.
The consultants indicated that 6" settlement would not be a surprise and that up to as much as 18" could occur. The preload will be made up of 15 to 20 feet of sand piled in and around the DG Building. No more than a 5-foot differential in the sand level .
between bays would be permitted. -
I The NRC questioned the effect of settlement and preloading on the
' condensate lines located under the DG Building. Fixed points for the piping, such as the Turbine Building wall, are also of '
x interest for the potential of cantilever effects. Bachtel explain;d i that the 20-inch condensate lines are encased in 24-inch lines l
' surrounded by concrete and resting in well compacted sand.
Instrumentation will be included to monitor the condensate lines.
Tht possibility of cutting the lines loose at the DG Building and the Turbine Building is also being studied. The condensate lines l- '. have no' safety-related function for the Midland design.
The NRC also expressed concern for the effect of settlement on the fuel oil lines under the building. CPC0 stated that re-routing of lines can be readily accomodated if necessary. This matter is also under review. .,. -
The NRC Resident Inspector asked for a list of the equipment, with i a discussion of the compacting capability and limitations of each, trsttr'for compacting the fill for the DG Building from elevation
, 618 to 628 feet. Bechtel will provide this infonnation.
- 5. Program Status Be tel summarized the activities completed, in progress, and planned for the future: E 6
I -
t g.,
{ ,
.E \
l i
' JAN.121979 g -
fr.
r (
- p. Activities Completed l (1) Boring program (2) Isolation of the. DG ofBuilding the electrical duct banks on the north side b.
Activities in Prooress (or soon to be initiated)
(1) Foundation settlement monitoring program (2) Preload instrumentation program (3) Actual preload of the structure and foundation.
(4) Filling the cooling pond to maximum elevation (Elevation 627)
(5) Complete construction of the' rest of the DG Building structure-
- c. Activities Planned '
~
\ * . . .
,/ (1) After removal of the surcharge, assure contact between footings and soil foundation material (2) Verify utilities and structure integrity
- 6. Project Schedule Bechtel presented the following project schedule information:
. Construction is 58% completed as of November 1978 Engineering is 80% complete Structural concrete is 97% complete Fuel load target date is November 1980
~ Earliest requirement for one diesel generator is January 1980 Current completion date for one diesel generator is January 1980 Latest date for one diesel generator is June 1980 r, i ' :. :. . -
i c.5e..~ "J : . . u l.
. .d j .m, , ' -
i ..i..
i .-
l-40,7 4 g 4:5 ' p ., e,,, . ( ~ [ f N I " .'
l 1 .
.= .-
....{. . ..
. g.-
f' i '
' JAN 121979 t- ,
-Bechtel emphasized that the installed-instrumentation will show tschedule is somewhat tentative.lwhen the preload surcharge Most settlement is predicted to '
' occur rapidly as the area is being preloaded and frequent readings will be taken during this period and used as a basis for further g projections. ' The rate of settlement will decrease thereafter and the total settlement is expected to be reached within a few months. -
CPC0 stated that if necessary, temporary diesels could be used during preoperational testing prior to fuel loading and that
,thist matter is presently under study.
- 7. _ Response to Open Items in NRC Inspection Report
' Bechtel addressed the open items included in NRC inspection report Nos. 50-329/78-12 and 50-330/78-12. CPC0 stated that a written response would be sent to I&E Region III to resolve the conflict between the FSAR and site implementing procedures:
a.
Conflict between FSAR Table 2.5-14 and Table 2.5-10 regarding the description of fill material and what was actually used -
in the random fill: Bechtel stated that this conflict was an oversight and that an FSAR amendment would be issued.
The NRC staff stated that any such amendment should address
/ both the previous and the adjusted entries such that the basis for the previous staff review is not obscured in the documentation.
.b.
- Conflict between FSAR Table 2.5-21 and Bechtel Specification C-210 regarding number of passes for compaction: Bechtel stated that cooling pondFSAR dikes. Table 2.5-21 is for the embankments for the
- c. FSAR Section 3.8.5.5 regarding expected settlement:
a Bechtel l stated that 1/2-inch indicated in the FSAR was a mistake and l that the FSAR would be amenced to correct this mistake, L Conflict between FSAR Figure 2.5-47 and project drawing
. ' regarding foundation elevation: Bechtel stated the elevations p ..
in the FSAR was also a mistake and would. be corrected, L
i~
L
- 4 Conflict i$ Bechtel Specification C-210 regarding compactive
. r4 . w . effort: Bechtel stated that Field Change Request C-302 [ .
- tN P dated 10/31/75 clarified this conflict and permitted the e i
" f a, . Bechtel Mod.1fied Protector" using 20,000 ft-lbs compactive d l .
effort rather than the ASTM standard of 56,000 ft-lbs.
\ \ .
- n g , *. .
s i ., . , - _ - . _ . . . . _ _ , _ . . . . . _ . _ _ . , _ _ . - - _ . _ . _ _ _ _ _ _ . _ . . _ _ _ _ ,
jf
.{.
- <.yy a ' . .
(} . __ . . . . _ , .
..y 1
j..?-3
, . 7 JAN 121979 p
r '
.t l
1 f.
/ 1 Conflict between Dames & Moore recomendation regarding lift 1 thickness up to 12 inches: of 6 to 8 inches and the Bechtel specification permitting
' Bechtel stated that the greater depth per- -
mitted by their specification should not matter because of E* performance qualification tests. However, the NRC was then
[ informed that the test qualifications performed were for Zone 1 l
,j clay only, and that no test qualifications on the random fill
. material using 12 inches was performed to qualify such lift thicknesses. Dr. Peck stated that the thicker the layer, the more differences in compaction through the thickness of the layer woulti occur.
g.
Tolerance of t 2% in moisture content permitted in Bechtel Specification C-210: Bechtel stated that this tolerance is in.line with industry practice.
Dr. Peck was asked his view on this
- 2% tolerance. He stated that the important question is "t 2% of what material."
Since the material used in the fill was variable, the t 2%
tolerance could cause a problem if the material is not
, consistent. .
- h. Cracks in the building structure: Bechtel stated that all cracks greater than the ACI ~318-71 limit would be identified s and repaired after the preload program,
,4. -FSAR question 362.2: Bechtel stated that the answer had been sent to NRC via FSAR revision 15 in November 1978.
CPC0 stated that the reply to the inspection report is in process, and that the reply will include copies of all data, slides, and .
drawings presented during this meeting.
In concluding remarks .CPC0 stated its intent to proceed with the preloading program as, described during the meeting.
In its closing coments,' the NRC staff stated that the proposed solu-tion is at the risk of the applicant and that NRC intends to review s
and e,yaluate this matter in accordance with the original compaction requirements as set forth in the commitments in the PSAR, The staff also stated that while attention to remedial action is important, determination of the exact cause is also quite important for verifying the adequacy of the remedial action, assessing the extent of the matter ?
relative to other structures, and ,in precluding repetition of such matters in the future. j
{V :
jp>. /f e e.
Darl Hood, PIject Manager .
' . Light Water Reactors Branch 4 Divisio'n of Project Management
Enclosures:
As stated j .- .
L. . . . - . _
7 -
'vr- @ w yw -'wtww9-wy.-ww w --cy -9P---m-eww--en,++-,--p1y-e --WT+=h e awte wmwe--..r--marie-mg re-o a w" w- e=m=w w- ww *1+uea.ewr
- D
~~ *
. y!' '.
'( (\
. . . . . ., s . _ ,
Yi.;;'
consurners Power. Company JAN 121979 f
r ces:
Michael I. Miller, Esq. -
Ishah Lincoln & Beale Suith,4200 One First National Plaza Chicago, Illinois 60670 Judd L. Bacon, Esq.
Consurners Power Company -
212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers Power Company
- 212 W. Michigan Avenue a
' Jackson, Michigan 49201 Myron M. Cherry, Esq. 8 One IBM Plaza Chicago, Illinois 60611 Mary Sinclair' '
5711 Summerset Drive
, Midland.. Michigan 48640 i.
Frank,J. Kelley, Esq..
Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 i
Mr. Windell Marshall Route 10 -
Midland,,
Michigan 48640 P
Mr. S. H. Howell Vice President l ConsuTeVs' Power Company
" 212 West Michigan Avenue Jackson, Michigan 49201 '
w a
- 4
. 4 g
- l
'. 1 l
s t
9
.. ja.,, -
(. '
t
^ '
ENCLOSURE 1 r ATTENDEES DECEMBER 4, 1978 MEETING JAN 121979 P.A[ Martinez,Bechtel '
Karl Wiedner, Bechtel
- 5. S. Afifi, Bechtel R. B. Peck, Bechtel Consultant
- W. R. Ferris, Bechtel M. O. Rothwell, Bechtel
- D. B. Miller, CPC0 - Project .
- J. P. Betts, Bechtel W. L. Barclay, Bechtel
- A. J. Boos, Bechtel G. L. Richardson, Bechtel
- D. E. Horn, CPC0 - QA W. R. Bird , CPCO-QA
- R. M. Wheeler, CPC0 - PMO
- C. A. Hunt, CPC0 - Engineering Services D; E. Sibbald, CPC0 Project John Dunnicliff, Bechtel Consultant
- Austin Marshall, Bechtel - Geotech
~
- Y K. Lin, Bechtel - Geotech
- B. C. McConnel, Gechtel - Geotech -
- B. Dhar, Bechtel _
- N. Swanberg, Bechtel
- Darl Hood, NRC LPM
- Gene Galla0her, NRC Region III (!&E),
- Daniel Gillen, NRC/NRC Geosciences
- Lyman Hiller, NRC/NRR Geosciences
-
- Ronald Cook, NRC Resident Inspector 4
- Present during both the 12/3/78 site tour and the 12/4/78 meeting.
e S.
e '# ,
sg a e
s ,
b
'.. }
s . .
e
.,.h; -
(
gpr
~
gn etosure 2
'4 * (S .c
SUBJECT:
' CPCo Midland Plant Units 1 & 2 i Diesel Generator BuildinB !
,' / JAIN 121979 !
i Meeting with NRC at Midland l WI DATE: December 4, 1978 I
- w. l T AGENDA I. , Introduction by CPCo l II.
History by Bechtel (N. Swanberg)
- a. Plant description
- b. Sattlement monitoring program c.
Brief history of site fill placement
- d. Settlemer.t of Category 1 structure e.
f.
Settlement of diesel generator building and pedestals
.g .
Review settlement data and drawings (SK-C-620/623)
Consultants III.
Soil Exploration by Bech'tel (S. Afifi)
- a. Soil borings
- b. Dutch cono penetrations
- c. Laborator*, ,es6s .
- d. Possible causes s
IV.
Consultant's Recoc:mendation by Dr. R.B. Peck and
, C.J. Dunnicliff *
- a. ,Preload
- b. 7nstrumentation V.
Status repo:t by Bechtel (B.C. McConnell)
- a. Activities completed
- b. Activities in progress
- c. Activities planned for future
- 1) Corrective action
- 2) FSAR conformanco i .
V1. -d -
lichedule by Bechtel (P. Mat tine:)
- a. Ov2rall project *
- b. Impact on project schedule c.
Schedulu for remedial measures
'~
O E
1 .
. l
- m. .
- s. .
. '$ f b n' . >
8 . . ,13 * ,
' ' ' p
- i. '
- * - - ~ . . . .
.:.6 / ..... .. .
i I. '
1pYj . . > '
- n. v.w .
\
,t VII.
(' Responses to open items in NRC Inspector's report l dated 11/17/78 by Bechtel (B. Dhar) '
'< y M 1979
- a. . Responses to Callaghar's concerns:
- 1)
. Conflict between FSAR Table 2.5-14 and Table 2.5-10 regarding fill material description 2)
Conflict between FSAR Table 2.5-21 and
' Specification C-210 regarding required
- number of passes for compaccion 3)- FSAR Section 3.8.5.5 - expected settlement
- 4) Conflict between FSAR Figure 2.5-47 and
~
project drawing regarding foundation p
elevation f.
^ 5)
Conflict in Specification C-210 regarding b'*
- compactive effort in test method ,
.h 6)
Conflict between consultant's recommendation c- and Specification'C 210 regarding a:ft
$' . thickness
- 7)
S.. * + 2% tolerance in moisture content permitted
.in Specification C-210 O-
- h. ': '
b.
- 8) Cracks in the building structure '
5 .' FSAR Question 362.2 (section 2.5.4.5.1)
- g. ' .
VIII.
=.
' Closing Comments by CPCo v
b.
sr.
( .' . .
- 5. .. .
.h Y. .
p;?'
4p y .. .
,V.y',', , ...
., .1 e, .
i?.*
- c. . . -
p,. - , .
.f;. . .c..,. a.
g ..
l V.*
- c~ .
,. .u ,
C.
- x. .
,.......as.,...
- ,. L _
n,. - .
. n. .- '
^ . ,
' g.. . . .
. .g.....
- u. . ,. .;, ; . . .......,..;,... . .
O, . . n:s 'd.<. f .:T W. l * . . - >
tj'Q..- '. O- l.;*u;D.,. .cht ..O b [p..O . '., ,
h H .: . ' . * .$.' : l
.;y.
. ga ; . .s ' ' g4 '
. - % . , 3
.: ', r,.?t . . ". ':.. ; . .. i. . :, . , ,
.~. e;..
'? *
.. l'
. ." , t. .y. p. . .f,.P. . .c;.1, . .. .. ; , '.. . , t ., -
'.4 . . ..
- u. ... . ' . . . . * .
~
r *
,. .~ : . ,. s ; k ., n: - 5. . ,; vtiq. .. , ..
W s
. .,..n.... . . . . . . <: 0 *
%~ .,.* s. . .
-' : .:.j..; 71 'n T*.,G . " .': - a 2'.; ...
~ '
- a' ' '
_;,, ,- .n .. . .r , . . . . , . . . . .' ,' :
- . 4~.!? ';*' ?* < '
. -; = .'
(~U '.- &
1 ,it+
h.*r.:d.. */, .m *, $.
I'
, Y ,* *
., i '-.. . , ,1"[..
, , (,
.=.-.'
's N.
[*d -
- *^ b' k . '#'.,#u.
.,...'s....-- , . ! * -
, , < < . . ' .* ' ., . 7 f .#.....,.%..[*,t....**,,.. .e- -
..* , s. +.. . < . . . . .., . .' .'. w'i ;1 w' ' . .
. .r , , , ,
. d * *
.g,. ,
.X ' 6 _ Attachment 12 I o b
--- # TQt.$'J EStS g{ PRoJsCTs snGL.NssAING ANo consraucitou-E=- - : SOWlf ouAUTY ASSURANCE OsPAATMENT 7
man ORAL COMMUNICATIO' RECORD caer rr.: so WRB 51-80 QA5-0 . ,1,,_c,2 aca rr ecamr.ams 5/12/80 t, 5/13 /80 a.ng m ar,. , WRBird (DHorn 5/13/80 only) ens er ems:smes erma amts) c. c.11. es .. . voc :.f
- bd .
ruman rr WRBird f ,,\ j -(( h [ ', J..'"
-c. _ _ (. - l . .; f .
i
- 7. . . .., ,
DIESEL GUTERATCR StrI'LIMriT PROBLDI - 50 5h(f) COMMISETS ON f- g', [ ~
IQUIPME3T QUALIFICATION [ l" [ 1
, .J- .
1 1
1 somr :r c=mnsm=r # l l
5/12/80 - 1.h Ga17 a gher asked my assistance in obtaining co=tactica eeuitment etal'ficatiens.
NRC had asked for their subr 1:tal. The latest 50.5L(f) resnonse did not sub it the esta.
~~
. . . . . _'4s said he had talked to D Horn several ti=es over the last veeks about the UFC conce-tr
~~~, aat_ the cualificatien records were not available. "he felievine t h ee tein* s ve- e -14.-
- 1) Cualificatiens are eensidered a cer-sment "Cuality ?*eerd." O ?" thaw d ea ' * -d**
hev e.n Cece . .4 urt t'v eid v -v - inse4*v ee *d- <-e va-v? Si f.-*.-. e e .- '--.--
is qualified is not good emengh - a qualification report is needed.
l l
l I stated that I would investigate the situation and take appropria.te action. Mr Gallagher g stated tha, he vould ask to. see; report on his next visit, and that there are other vehicles to acce=plish their needs.
5713/80 'Je called .st Gallagher back to give him a status of wht: :-v investi: cation revealted and what specific actions ve had directed:
. . . . y v. .
==
- 1) Bechtel vill release an offief el desirn diseleru_-e (~ost lik elv SC'7 5 c ' e- a ' '* - ~ d --
C-211) vhich vill list the eenir ent cualifiettiene "' *he li-d* s c f *he anelet d ea .
- {:
(OVER) r ,m-ve,v- a w g=&en*vw,,- w. q - e w y -,-y .m w e , . w r p-g,g%,,v.,,,4e, F- r-are- w ~re m- de.www, w- w w w -e-wwwwws ,--.r===+=wwwe-----== = -- ="*'-+--$-
~
y....--
~
i
- .~; . . .. .. ,, ..,,n... . .
Pgs 2 et 2
- 2) Bechtel Engineering had completed their review of the qualification report - .
and Consumers vill be finishing up cur review today.
Mr Gallagher vendered hov ve could have been placing soils since last summer if a qualification report had not been reviewed and approved by Quality. He stated it vould be a very serious situation if the analysis of the report showed I
there was equipment deemed to be not qualified which had been used for soils !
placement. Den Horn stated that his review to date has resulted is cene questions i on qualifications to-. placement of clay but that no Q placcen c have abeen made with '
' this equi;mest. The qualification of the equipment for piscament et samis appear to be . substantiated. To our knovledge, no Q placements had been made prior to Escht
.. - _e),.Erojeet Engineering's release of the equipment in vriting to the field.
Wa stated that the qualification report vs.s planned to be submitted in a June '
suhaittal.-
N
., was/1r Editorial Note - Neithor' cur 50 5h(f) response nor the 3echtel program requirements
, require a Quality Assurance line isvolve=ent in the Engineering activities to certify the qualification of the compaction equipme=t. FIC 1.100 places the qualification and records for .. =-
qualification of compaction equipment with Geotech. . . . _ .
CC: 'JWCook, ?1h-113A JLCorley, . Midland -
LEcurtis,'3echtel AA
. IZDavis, 3echtel-Midla.M
,mL A.Creis_baeh, sc- S.eehtel-Midland W4 DE!!orn Duc_a.m 5g ne.
BWMargugido, JSC-220A JMilandis, 3echtel AA DBM111er, Midland JARutgers, Bechtel AA 88 meesse.
eee ease.ames..
a 1
p ;
. I
_ l
. ~ . . . _ . . , _ . _ . . , . . _ _ . . . . . - . . _ . , . _ , . , . _ . _ , . . . _ . . _ _ . _ _ . . . . _ . _ . . _ _ _ _ _ . _
To File Attachment 13 raou TCCooke/RM -
~(
Consumers 04rc . August 7, 1979 . -
POW 8f suusccy MIDLAND PROJECT CWO 7020 PRE-MEETING WITH CONSULTANTS bg g File: B3.0.3 Serial: CSC-4274 UFIl-00234.S. fjt3*
L ,,,,,
cc Attendees.
CSKeeley, P14-408B
~
DBM111er
'KCBrooks (2) '
q ' Attendees: *
, Karl Wiedner, Bechtel Power #
, Phil Martinez, Bechtel Power Sherif Afifi, Bechtel Power Dr. Ralph Peck, Consultant Dr. A. Hendron, Jr., Consultant
'Dr. M. T. Davisson, Consultant Tom Cooke, Consumers Power Companyf.
There was a brief discussion on the various options. One of the main reasons for Option Five (Areal Dewatering) was that it grew to a large extent out of the dewatering process for Option One. The consultants expressed the opinion .
that we had to answer liquefaction questions wherever anyone might think they .
could occur (for exaraple, the control tower at 6KSF loading). It could be a real thorn in the job at a later date, andareal dewatering is the only clean method. It is very hard to argue against dewatering, and it would be very difficult to prove the effectiveness of grouting. The question was asked about the water e. hat could be grapped in clay. The consultants responded that over the long haul, it would drain with permanent drainage and could be proven by piezometers. While peripheral wells would probably do the job, there would be some. intermediate wells. Any vein of water would be drained. Piezometers would convincingly prove that the area was dry. The construction dewatering process for the Auxiliary Building electrical penetration areas will assist in determining how much dewatering a'nd how many wells, etc., are required.
P. Martinez indicated that Bechtel would have to take another look at the design calculations in the foundation areas. i l . l
[ The Auxiliary Building electrical penetration area is a high narrow structure l
! with a torsion box at the lower portion. The soil'was designed to take the hori-l zontal shear. The low soil blow counts values indicate that this structure is possibly being cantilevered tn some extent off of the control tower. Dr. Peck cxpressed the need for the design basis for this structure. Dr. Hendron indicated that- the borings were not necessarily indicative of what was beneath the structure.
A parametric study for the structure should be made based on a range of soil prop- . 4 perties. A quick rough analysis should first be done, followed by a detailed I analysis. Karl Wiedner discussed the possible outer end settlement and his theory on how the structure had possibly picked up a cantilevered load during construction phases.
p l - .
.,._m --
L
_ .. -. . - - . . _ . - - - - - - - - ~ ~ - - - - ~ ' - - - - - -'
._ _ . _ . . . - . _ ___ .. . m ._ __. . .
.- 1 Page 2
' File-Midland Project 'CWO 7020 '- Pre-Heating with Consultants
' File: B 3.9. 3 Scrial: CSC-4274- UFIl-00234 .
August 6,f1979 ,
Tom Davisson then mentioned that, since we were thinking of permanent dewatering,. ,
a different 'underptnning method may b acceptabic (ona that would take vertical loads only). The Auxiliary Building control tower and the material below the electrical penetration areas have potential for horizontal shear resistance. The' three options'would be to: (1) do nothing, (2) supply something for vertical loads only, and (3) supply something for vertical loads and horizontal shear.
The first step would be to check the horizontal shear resistance required.
Possibly horizontal support could be picked up from the Reactor Building and/or Turbine Building. . If we remove material and fix the end of the Auxiliary Building electrical penetration areas, we still would have to analyze for an unsupported mid span. Caissons were mentioned as another option. It was noted that even clay with en average blow count of three would have modest shear strength. The con-sultants noted that they did not have sufficient design information. Karl Wiedner' and other Bechtel personnel present did not have all the answrs on the design basis at the time of this meeting. However, at T. C. Cooke's suggestion, the con-sultants agreed to' formulate their questions in writing for kehtel response.
w u e A.a m +3 M W hetA The consultants noted that in their opinion, for the underpinning of the Auxiliary Building elecer a penetration areas was very low, especially when compared to the estimate of for permanent dewatering. They also atated
- that we definitely have a diese -generator liquefaction problem although the sand
' would probably never actually liquefy during an earthquake. The problem was the difficulty in providing calculations which verify this and would not be subject to argument. . -
A brief discussion then followed concerning possible liquef action regarding util-ities, sand backfill around buildings, tank farm, railroad bay and control tower, etc. For the tank farm, railroad bay and control tower, a safety factor of 1.5
' is generally acceptable. However, if for any reason, ' the acceleration criteria goes up in the future, Dr. Peck felt that it may be difficult to prove no 11gue-faction problems. The borings may not be completely satisfactory for the purpose of proving beyond a shadow of a doubt that everything was satisfactory because needlessly conservative decisions may be formulated on the "what if" type questions.
l The consultants noted that they were still in favor of a general dewatering program, especially in light of possibly more stringenti seismic requirements in the future and the knowledge now availa.ble to the effect that generally speaking sand exists in more areas _than originally anticipated in the power block area. The consultants believed that the permanent dewatering program, in general, was a must. The temporary dewatering system would show how the permanent system would work. The water can be lowered sufficiently to make the site acceptable in the new licensing arena. Dr. Peck etated that he could attend a meeting on the 18th of July in Washington to discuss the situation with the NRC.
4
-g,,,,-.., , w-s-y- .,p+.w..,m--,,-- +, ,-.p ,- g,re,.uya.,r-...--,-%, , ,_ ,sg-se-w=wt--si-se--s***=r+-e"-u------.-----"*'~e*
1 i
To File F.on TCCooke. .f' ggg 04tc August 10, 1979 POW 8I company Suescer MIDLAND PROJF.CT CWO 7020 - PRE-MCETING AND CENERAI, MEETING WITH CONSULTANTS File: B3.0.3 g ,,,,
UFI: 00234-S Serial: CSC-4306 co .c sro.oc.cc cc Attendees RWheeler CSKeeley, P14-408B KCBrooks(2)
DBMiller p.tendees: -
Karl Wiedner, Bechtel Dr. M. T. Davisson, Consultant Phil Martinez, Bechtel Chuck Could, Consultant Sheriff Afifi, Bechtel Dick Loughney, Consultant Bimal Dhar, Bechtel Tom Cooke, Consumers Power Company' Al Boos, Bechtel Don Sibbald, Consumers Power Compnny A-t Atnold, Bechtel Don Horn, Consumers Power Company
. Dr. Ralph Peck, Consultant Thiru Thiruvengandam, Consumers Power Co.
Dr. A. Hendron, Jr., Consultant
{ Please note that serials CSC-4274 and CSC-4255,'above subject, omitted the location and dates of the meetings. Both meetings were held in Denver, Colorado The Pre-Meeting (CSC-4274) was held on June 27, 1979, and the General Meeting (CSC-4255) was held on June 28, 1979.
Picase attach this letter to your copy of the meeting notes.
s1d
' Fe'bruary 12, 1980 ~
UNITED STATE $ j NUCLEAR REGULATORY COMMISSION j WASHINGTON, D c. 205sf INFORMATION REPORT
. For: .The Commissioners -
. 1 From: . Victor Stello, Jr. , Director Office of. Inspection and Enforcement 0.) '
Thru: Executive Director for Operations ,
Subiect: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE g
Purcosa: The purpose :of this.. paper is to informt the Commission regarding 5 the. status of effort's by the Office of Inspection and Enforce-
. ment in the enlua , ion .of licensee performance.
. . 1 Discussion: In October 1978, IE submitted SECY 78-554 " Licensee Regulatory Performance Evaluation,' which requested,. and subsequently obtained, Commission approval'for a two year trial program for
- 1. evaluating licensee regulatory performance. " Regulatory--
performance" was defined as the licensee's ability to meet regulatory requirements and to. avoid reportaole events.
~
> SECY 78-55d indicated that an " integrated methodology" would be developed that incorporated selectad aspects of the three previces'ly. considered methods (Statistical, Trend Analysis, and Regicnal Survey) that were described in tne paper. The objec -
tives of this methocology were cefined as:
. Identification of factors that lead to different levels of regulatory performance; Effective and efficient use of NRC inspection resources; f and .
Evaluation of various aspects of the NRC inspection program.
The trial program was develooed, but was never imolemented because of the Three Mile Island (TMI) Accicent.
A program for the comorenensive overview Of licensee cerformance nas been included as Task I.3.2 in :ne "Ac-ion Plans for Imolementing Recommencations of :ne P esicent's Commission anc
.
- hp w.
M. I. Nornourg, IE 19-I5152 d6 6 goo oge/of
Other Studies of THI-2 Xccident" (NUREG-06G0). This program is described in the enclosed paper a~nd is entitled " Systematic Assessment of Licensee Performance" (SALP). The objectives of SALP are:
. Identification of unacceptable licensee performance;
. Improvement of if censee performance;
. Improvement of IE Inspection Program;
. -Providing a basis for NRC management's allocation of resources; and
. . Achiev'ing regional consistency by appraising licensee
. performance from a national perspective.
The SALP Pro' g ram has been developed for power reactor licensees, but may, with modifications, be applicable to major materials licensees.
As was the case with the Licensee Regulatory Performance Evaluation, the SALP Program is designed to Jdentify licensees whose regulatory performance warrants increased emphasis in
. ', licensing and inspection activities. If such licensees are -
identified, appropriate action will be initiated to upgrade the licens,ee. performance; a major thrust of the SALP. The method-ology'has'five (5) basic features:
. Evaluation of licensee performance by a board of regional inspectors, regional supervisofs, and the NRR Project Manager (NMSS Project Manager for Materials licensees);
. Determination by regional management of the action necessary to upgrade performance;
. Holding annual meetings with licensee management to discuss the regional evaluations and planned actions;
. Review of the evaluations of licensee performance and planned corrective action by a SALP Review Group, composed of senior NRC management personnel, with inputs from the regional evaluations, NRR appraisals, and the appraisals of other NPC offices (i.e. , AE00, PAB, etc.); and
. Recommendations by the SALP Review Group to the appropriate NRC office director for major enforcement sanctions, license modifications, or increased (or decreased) inspec-tion emphasis (frequency or scope) as warranted by the licensee evaluations.
9 y p.. ,. ,, , , - . - - ~ , -
.w.-.,
3-Selected portions of the three previously considered methods of performance appraisal have been incorporated into the regional evaluations of licensee performance. An IE Manual Chapter (MC) defining the program for the regional evaluation of licensee performance is ' currently being reviewed by the regions. 'This MC will be issued in March 1980.
Regional evaluations will begin in April 1980 and will be cor.pleted in June 1980. The composition of the SALP Review Group, the procedures for Review Group operation, and details of the evaluations by the offices providing input to the Review Group, will be finalized by June 1980. The initial evaluations of the.SALP, Review Group will be completed in December 1980.
Coordination $, The Offices of Nuclear Reactor Regulation, Management and Program Analysis, Analysis an# Evaluation of Operational Data, and Standards Development concur. The Office of Nuclear Material Safety and Safeguards has no. objection to the proposed program for reactor licensees.
The Execut.ive Legal _ Oirector has no legal objections.
.s Yf
-Victor Stello, Jr.
~
, ., .y..,
Director Office of Inspection and Enforcement
Enclosure:
" Systematic Assessment of ,
Licensee Performance" This paper is scheduled for consideration at an open meeting on February 14,
. ,, . . . - . - . , , . , .- ,_,,-,--m
, . , , . . , _ ---,,--m_ . . , , , . - , - , , , , , . . . - - - . . . ,,
l l
SYSTEM TIC ASSESSMENT OF LICENSEE PERFORMANCE T. INTRODUCTION l
This. paper describes the Systematic Assessment of Licensee. Performance (SALP) which is a refinement of a program previously referred to as the I
" Integrated Approach" to Licensee Regulatory Perfomance Evaluation ;
(LRPE). SALP, like LEPE, is defined as an evaluation of the ability of a licensee to moet regulatory requirarcents and to avoid significant events that appear to be directly under the coatrol of the licensee.
The SALP Program was.c'eveloped for pc.,er reactor facilities in operation and construction,"and is based on certain aspects of previously conducted NRC studies, with the' methods ~.substantially modified. The SALP Program, with modifications, may be applicable to major fuel facilities and major by produ'ct licensed facilities. ,
The requirements for licensee perfomance appraisal were first established in NUREG-0397, " Revised Inspection Program for Nuclear Power Plants",
which includes a national performance appraisal capability that provides the following elements:
Evaluation of the performance of NRC licerisees fr'om a national per-spective-Evaluation of the effectiveness of the NRC inspection program; and
+ 4 n, -
Confimation of the objectivity of NRC inspectors.
Ouring October 1978, IE submitted SECY 78-554, " Licensee Regulatory
' Performance Evaluation", to the Commission. As described in SECY 78-554, the objectives of LRPE were as follows:
Identification of factors that lead to different levels of regulatory performance; Effective and efficient use of HRC resources; and Evaluation of various aspects of the NRC inspection program.
SECY 78-554 described three methods (Statistical Method, Trend Analysis Method, and Regional Survey Method) of licensee performance appraisal which had been studied by NRC. It also .]roposed the implementation of a trial program which was referred to as tie " integrated approach
- rathod-ology to Licensee Regulatory Performance Evaluation (LRPE). This method-ology was to be used to evaluate operating reactor licensees using l'J78- "
1979 data. The trial program was developed, but its implementattun was interrupted by the Three Mile Island Accident.
As a result of the investigative studies of the Three Mile Island Accident, a program for the comprehensive evaluation of licensee perfomance has
~ ;
~
l been 'Indluded as' Task I.B.2 in the " Action Plan for' Implementing Reco:uendations of the Presitfent's Commission and Other Studies of THI-2 Accident" (NUREG-0660). The program outlined by Task I.B.2 is a refine-ment of the LRPE riethodology. This program which is the subject of this paper has been entitled the Systematic Assessment of Licensee Pernrmance (SALP) to coincide with the recommendations of the Kemeny Report. The objectives of SALP have been defined as: ;
Identification of unacceptable licensee performance; Improvement of licensee performance;
. Improvement 8f .I.E' Inspection Program; Prb,viding a basis fer NRb manacjement's allocation of resources; and
' Achieving regional consicncy by' appraising licensee performane from a national perspective.
These oSjectives will be accomplished through the performance of periodic
' eva10ations of licensees by IE and NRR. The evaluations will be reviewed by a SALP Review Group of senior management personnel from NRC offices.
The results of the evaluations, the reviews by 'the SALP Review Group, and
, the plans for appropriate action by NRC will be documented and distributei -
to'the appropriate office director, to the licensees, and to the Public Document Rooms. In addition, the regional offices will hold annual management meetingi%ith each of the evaluat4d licensees to discuss the results of the evaluations.
The appropriate action to upgrade licensee performance will be initiated by the regional offices as a result of the evaluations and may include enforcement action, or increased inspection frequency and scope.
- 2. INTEGRATED ASSESSMENT OF LICENSEE PERFORMANCE
- a. Procram Inouts Several groups within the NRC will provide inputs to SALP as follows:
(1) The IE regional office will perform an evaluation of the performance of each licensee semiannually. This evaluation will be used to determine the need for an increase or decrease in the' frequency and scope of regulatory activities. The region will document the results of the evaluation and their plans for action, and forward this documentation to the SALP Review Group.
(2) HRR Project Managers will participate in the regional evaluations discussed in (1) above. The NRR Project Managers and technical support program personnel will also provide input i
l I
1
.a- . . .- - -
to the SALP Review Group. In addition, NRR will perform an independent study of the management capabilities and overall training of licensee employees. The results of this study will be suomitted to the SALP Review Group for consideration duiing their initial evaluations.
(3) The IE Perfomance Appraisal Branch will perform Management Appraisal (MA) and Program Appraisal (PA) inspections at licensee facilities. The reports of their inspections will contain' an appraisal of licensee management which will be forwarded to the SALP Review Group. All licensees will not receive these inspec-tions during the first two years of this program. However, it is expected.that the number of licensees inspected will be
, sufficient to verif regional consistency.
'(4)' Other NRC Offices (such as AEbO, etc) may provide input to the CALP Review droup as apcraisal methodologies are developed with proven correlation to t he safety of operations.
.The regional evaluation discussed in (1) above will utilize ,
appopriate r portions of the three previously developed methods of perfomaca evaluation. The details of the above. evaluation / appraisal techniques vill be discussed in Section 3 of this papir.
- b. # Review of Evaluation Results
. w.
Review o,f HRC ' evaluation result [and the' appropriate plans for upgrading performance will be conducted by the SALP Review Group consisting of senior managers from the.NRC offices appointed by the Executive Director for Operations. The Review Group will provide an overview function of the evaluations and render an assessment of the safety adequacy of each facility and the adequacy of upgrading plans. Based on the findings, the Review Group is specifically charged to recomnend major enforcement sanctions or license modifi-cations to appropriate office directors. The Review Group will also confim the consistency of regional evaluations and the regional implementation of HRC inspection programs.
The SALP Review Group, in addition to receiving inputs from regional evaluations, will receive inputs from NRR, IE Headquarters, and from ,
other NRC cffices as appropriate. The Review Group will convene at least once every six (6) months and revfew the evaluations of the ifcensees that are classified as needing " increased inspection scope /fraqu6ncy." The remaining licensee evaluations will be eval-uated once every twelve (12) months.
- c. Feedback of Evaluation Results The primary cbjectives of SALP are to identify unacceptable elements of licensee performance and to subsequently improve (upgrade) licensee l pe rfomance. The former objective is achieved by the regional l l
1
. __ l
Y e
)
l l
-4a 1
eviluations and the reviews y the SALP Review Group, but to improve performance the results of these evaluations must be communicated to NRC management. The results of the regional evaluations and the recommended plan for the appropriate corrective action is forwarded to the Regional Director for review and approval. The results of the SALP Roview Group are forwarded to the appropriate-office director indicating a concurrence with the proposed regional action or recem-mending additional or alternate action.
NRC offices providing evaluation information will document the results 'of their evaluations with distribution to the licensee, POR, and to the SALP. Review Group. In addition, the region will submit an interoffihe memorandum detailing the future plans for action by th,e region to correct the deficiencies identified during the evaluation. ,
The Review Group 'will issue a repo~rt at the conclusion of their periodic reviews to document the extent of their concurrence with the regional' evaluations and proposed actions; or their recommenda-tions for additional or alternate action.
Annual ceeting's will be conducted by regional management with the managements 'of the licensees evaluated by'this pfogram. These meetings vill be utilized to discuss the results of the licensee -
performance evaluations and the NRC's general plan of action for correcting deficiencies.
- a. .. v.. . .
- 3. METHCCOLOGIES
- a. Recio: 11 Evaluation Each region will perform a detailed evaluation of their power reactor licensees semiannually. The evaluations will be performed by a board of the inspectors (including the resident inspector) and supervisors involved in the inspection program for that licensee.
The board will also include the HRR Project Manager for the facility.
The board will consider the enforcement acticas, deficiency / event reports, technical and management performance, and safety attitudes of the licensee. The ovaluations will also be based on the observa-tions of the board members and their judgments of the licensee's performance. The evaluation will be the board's consensus of licensee performance; however, dissenting opinions with substant 4ve ccments will be included and transmitted to the SALP Review Group, for concurr'ent evaluation. A number of functional areas will be evaluated by the board and a classification of " increase," " decrease,"
or "no-change" in the frequency and scope of inspection effort will be assigned for each functional area. The board will also provice an overall evaluation of the licensee and a detailed plan of the appropriate actions to upgrade performance.
w -e-a-, a y ,c --,. ,
l
- ; l 5
l
.The evaluation of each functional. area will include the folif*ing considerations: l l
. Adequacy of administrative controls;
. Adequacy of supervisory review in the f-nctional area;
. Adequacy of training and qualification of personnel;
. Adequacy of documentation and records control systems;
.- Overall,, effectiveness in complying with NRC requirements;
., Attitude in' assuring safe operations; and
~, , .
Significant performance devia'tions or trends noted from previous evaluations.
The board's evaluation of the licensee's enforcement history in each
. functional area will include identified items of noncompliance.and esdalated enforcement actions. A statistical analysis will not be perforced on noncompliance data; but an indepth analysis of indicated trends and sanction points will be determined and will be considered
, in the evaluation. -
The board's reyiew of deficiency / event reports will consider the number,'sicjnificance and repetitive nat0re of the non-routine events er construction deficiencies in' each functional area. The board will provide an indepth analysis of these reports to identify adverse trends (causally-linked events) which indicate insufficient attention to the correction of the events or insufficient capabilities of licensee management in the functional areas. This analysis is similar to that developed in tha Trend Analysis Method described in SECY 78-554.
The NRR Project Manager will provide input on the licensee's l performance in those functional areas in which he is knowledgeable. I A manual chapter is being developed that specifies the functional areas to be evaluated and the methodology for performing the evalua- I tions. l This evaluation differs from the Regional Survey Method performed by the Hays As'sociates (referenced in SECY 78-554) in that it is a structured eYaluation Which represents the consensus of regional personnel and is supportable by inspection results and event reports as opposed to the Hays questionnaire which contained anonymous unsupported opinions.
~
t 3
" will perform an evaluation of each power reactor licensee semiannually
'and will submit.the evaluation to' the.SALP Review Group for inclusion in their review. The details;of this evaluation are yet to be developed.
In addition, the NRR QA Branch and selected contractors are developing acceptance criteria to describe the capabilities (number of people, kinds of people, background, experience, training, etc.) required of licensee management. This program is Task I.8.1 in NUREG-0660.
.They will subsequently evaluate all licensees against these criteria.
Deficiencies identified ~in this study will be discussed with each licensee and will be documented inca report. NRR plans to complete this effort in the spring of 1980.. The results of this one-time
- study will be pro'vided to the SALP' Review Group for their initial evaluations.
- c. farformance Aooraisal Branch (PAS) Insoections ,
Management Appraisal (MA) Inspections will. be per. formed by the PA8 on selected licensees in each Region. The objectives' of these inspections are to provide a national perspective of licensee -
', performance; to identify performance traits that licensees may have in comm9n; and.,to confirm inspector objectivity.
1 The HA; inspections are conducted at the licensee's corporate offices and at the reactor site with emphasis on evaluating the effectiveness of the licensee's canagement in controlling licensed activities and in providing technical support to ensure compliance with regulatory requirements and safety of operations. Results of these inspections
-will be furnished to the the SALP P,eview Group.
The technique for appraising licensee management performance is discussed in detail in the PA8 annual report for FY 79. Basically, the MA inspection involves an appraisal of the licensee in a number of functional areas. The appraisals in these functional areas are based on a mangement control system which should contain the following features: l
. '4ritten policies and procedures l
. Adequacy of the program to cover current requirements and guidance
. Qualification and training of personnel implementing the program
. Awareness by the personnel icplementing the program of their I responsibilities l l
l
. . . - . . _ , _ . . . _ _ ._ ...-.- _ _.. ~.- . - . - . _ ~ . - -.~, - - - - - ~ . .- ~ . - - - - - -
. y.
~
. Implementation of the program IE Program Appraisal (PA) Inspections will also be conducted. . These inspections are primarily designed to determine IE program effective-ness; however, information from these inspections will be provided to the-SALP Review Group when the inspection results indicate a licensee performance problem or a significant program weakness.
Manual chapters 'are being developed specifying the methodologies of the FA and PA inspections and appraisals.
e e
e a
- , f
- * +
s , , te O
.'. h
'\ u ' i, *; , .
6 4
9 l
l l
- - . . . . - . . -