ML20126L859
| ML20126L859 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/03/1979 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20126L803 | List: |
| References | |
| NUDOCS 8106090700 | |
| Download: ML20126L859 (14) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSlor y 5
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- oLEN E LLYN, ILl,1NoIS 60137 April 3, 1979 I
MEMORANDUM FOR: Harold D. Thornburg, Director, Division of Reactor Construction Inspection, IE FROM:
James G. Keppler, Director
SUBJECT:
ENFORCEMENT ACTION RE: MIDLAND DIESEL GENERATOR 4
BUILDING AND PLANT FILL AREA As you are aware, we have sent to Consumers Power Company a report on our two meetings held with th6m and a report of the investigation into the causes of the diesel generator building settlement.
In my memor-andum to you dated March 12, 1979, I summarized our findings and our concerns resulting from this investigation.
In view of NRR's involvement in the technical issues in this case, and the need for a determination as to the materiality of FSAR statements we consider to be false, we are not in a position at this time to recommend specific enforcement action which should be taken.
Attached to this memorandum are the specific FSAR statements and the
' basis for our conclusion that they are false. Also attached are copies of our letter dated March 22, 1979, which transmitted the Investigation report to the licensee and a draft Notice of Violat:on setting forth the items of noncompliance based on the investigation' findings. The draf t Notice of Violation includes all of the FSAR discrepancies described in Attachment 1 as examples of noncompliance ieith Criterion III of 10 CFR 50, Appendix B.
If it is determined that any of these matters constitute material false statements, we assume they would then be treated separately, and removed as examples of noncompliance with this criteria.
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2-April 3, 1979 Harold D. Thornburg We request that the items of noncompliance be given technical and legal
. review and that a determination be made of the materiality of FSAR dis-crepancies so that upon resolution of the~ technical' issues, we will be in a position to move more promptly toward taking enforcement action.
0 Yi by
' kames G. Keppler Director Attachmsnts:
1.
FSAR False Statements L
2.
Draft Notice of Violation 3.
Ler dtd 3/22/79, with Investigation Report cc w/ attachments:
,D.' Thompson, IE 4
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a Midland FSAR Statements 1.
Statement Section 2.5.4.5.3 Fill, states:
"All fill and backfill were placed according to Table 2.5-9."
Table 2.5-9, Kinimum Compac' ion Criteria, contains the following:
t Compaction Criteria (1)
" Function Designation Type Degree ASTM Designation Support of Clay 95%
ASTMD155{yj6T structures (modified)
(1)For zone designation see Table 2.5-10.
(2)The method was modified to get 20,000 foot-pounds of compactive energy per cubic foot of soil."
Section 2.5.4.10.1, Bearing Capacity, states:
" Table 2.5-14 shows the contact stress beneath footings subject to static and static plus dynamic loadings, the foundation elevation, and the type of supporting medium for various plant structures."
Table 2.5-14, Summary of Contact Stresses and Ultimate Bearing Capacity for Mat Foundations Supporting Seismic Category I and II Structures, contains, in part; the following:
" Unit Supporting Soils Diesel Generator Controlled c'ompacted Building cohesive fill.
Finding Construction Drawing C-45, Class I fill material areas, specifies the foundation caterial f or Class I structures to be Zone 2 =aterial which is identified in FSAR Table 2.5-10, Gradation Rang'es for Fill Material, as Random Fill and is described as "Any material free of humus, organic or other deleterious material." It was ascertained that materials other than " clay" or " controlled compacted cohesive fill" were used for support of structures.
Midland FSAR Statements.
2.
Statement Se'etion 2.5.4.10.3.1, Plant Layout and Loads, states:
"The building loads superimposed by the structures on undisturbed soil or compacted i
fill are given in the soil pressure plan, Figure 2.5-47."
Figure 2.5-47, Soil Pressure Diagram Category I and II Structures, shows the superimposed load density for the Diesel Generator Building to be 4.0 KSF (4000 lbs. per sq. f t.).
Finding It was ascertained through a review of the settlement calculations and an interview of the individual who performed those calculations that 3.0 KSF was used.
3.
Statement Section 2.5.4.10.3.3, Soil Parameters, states: "The soil com-pressibility parameters used in the settlement calculation are presented together with soil profile in Table 2.5-16."
Tabic 2.5-16, Idealized Soil Profile and Parameters for Elastic Half-space Settlement and Heave Analysis, contains the following:
Averggy Elevation c'#
Idealized Interval Thickness 1+e Layer Soil Type (ft)
(ft)
A Fill (CL) 634-609 25 0.003 B
Fill (CL) 609-603 6
0.003 NOTE:
Final groundwater table is taken at elevation 627.
(1) Values were estimated from the mathematical relationship between Young's Modulus and Compression and rebound indexes and averaged with those obtained from consolidation tests. Young's Modulus was estimated from empirical relationship with shear strength.
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' Midland FSAR Statement.
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Finding It was ascertained through a review of the statement calculations for the Diesel. Generator Building and an intervAew with the indi-vidua11who performed' these calculations that an index or compress-ibility of 0.001 not'0.003. was used for the elevation interval
'603-634.'
4.
Statement-Section 2.5.4.10.3.5, Analysis, sta:es: "For settlement compu-s tations, a total of 141 settlement points are established on a grid and at selected ' structure locations las shown in. Figure '2.5-48.
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. To account' for possible time-dependent relationship, the estimated total settlements at each of the 41 points were obtained respectively by adding 25% of the calculated settlement values of loading Case A to the calculated ultimate settlement values of loading Case B.. These values'are presented in Figure 2.5-48."
'Section 3.8.4.1.2, Diesel Generator Building,: states:
"The walls' are supported by continuous footings with bases at elevation 628'-0".
Each diesel generator rests 6n,a 6'-6" thick reinforged
. concrete pedestal which is not structurally connected to the building foundation for purposes of vibration isolation."
Finding It was ascertained through a review of the settlement calculations for the Diesel Generator Building and an interview with the indi-vidual who performed these calculations that' the data in Figure 2.5-48 regarding the Diesel Generator Building are based on
. calculations performed on the erroneous assumption that the Diesel Generator Building was constructed on a mat" foundation.
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Statement Section 3.8.5.5, Structural Acceptance Criteria, states.: " Settle-ments of shallow spread footings founded on compacted fills are estimated to be on the order of 1/2 inch or less.
These settle-ments are essentially elastic and occur as the loads are applied."
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. Midland FSAR Statement.
Finding f
It was ascertained through an interview with the individual who wrote this section of the FSAR that the above statement was taken from the Dames and Moore report submitted as part of the PSAR.
He assumed the statement was valid for inclusion in the FSAR. He said there was no other basis to support the statement.
(NOTE: In this regard the licensee has subsequently stated this statement ".
. is not applicable to the as-built configurations and conditions of the diesel generator building and has been elim-
.inated from the FSAR in Revision 18.")
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. c Appendix A NOTICE OF VIOLATION
' Consumers Power Docket No. 50-329 Company.
Docket No. 50-330 Based on the results of an NRC investigation conducted on December' 11-13, 18-20, 1978, and January 4-5, 9-11, 22-25, 1979, ic appears, that certain of your activities were not conducted in full compliance with NRC requirements as noted below.
These items are
-infractions.
1.
10 CFR 50, Appendix B, Criterich III requires, in part, that
. measures shall be. established and executed to assure that regula-tory requirements and the design-basis as specified in the license l
application for structures are correctly translated into specifi-cations, drawings, procedures and instructions. Also, it provides that measures shall be established for the identification and control of design interfaces and for coordinates among partici-pating design organizations.
CPCo Topical Report CPC-1-A policy No. 3, Section 3.4 states, in part, "the assigned lead design group or organization (i.e., the NSSS supplier, A&E, supplier or CPCo) assure that designs and materials are s'ultable and that they comply with design criteria and regulatory requirements."
Attac'hment 2 a
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1 CPCo is committed to ANSI N45.2 (1971), Section 4.1, which states,
'in part, " measures shall be established and documented to assure that the applicable specified design requirements, such as a design basis, are correctly translated into specifi-regulatory requirements.
cations, drawings, procedures, or instructions."
t Contrary to the above, measures did not assure that design basis were included in drawings and specifications nor did they provide for the identification and control of design interfaces.
As a result, several inconsistencies were identified in the license application and in other design basis documents. Specific examples are set forth below:
Construction Drawing C-45 (Class I fill material areas) a.
specifies the foundation material for Class I structures to be Zone 2 material, defined as any material free of humus, organic or other deleteriotts. material with no restrictions or gradation while FS AR Tables 2.5-9 and 2. 5-14, indicate the foundation material for support of Class I structures to be controlled compacted cohesive (clay) material.
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Appendix'A-.
- b.
The FSAR is internally inconsistent in that FSAR Figure 2.5-48 indicates' settlement of the Diesel Generator Building to be on the order of 3" while FSAR Section 3.8.5.5 (structural acceptance criteria) indicates settlements on shallow spread footings founded on compacted fill to be on the order of 1/2" or less. The Diesel Generator Building is supported by a continuous shallow spread' footing.
b-The'desihnsettlementcalculationsforthedieselgenerator c.
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and borated water storage tanks were performed on the assumption of uniform mat foundations while these foundations were designed and ' constructed as spread footing foundations.
1 d.
' The settlement calculations for the Diesel Generator Building indicate a load intensity of 3000 PSF.while the FSAR, Figure 2.5-47, shows a load intensity of 4000 PSF, as actually constructed.
i e.
The settlement calculations for the diesel generator building were based on an index of compressibility of the' plant fill between elevations 603 and 634 of 0.001.
These settlement 9
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values were shown in FSAR Figure 2.5-48.
However, FSAR, Table 2. 5-16, indicates an index of compressibility of the same plant fill to be 0.003.
f.
PSAR, Amendment 3, indicated that if filling and backfilling operations are discontinued during periods of cold weather, all frozen soil would be removed or recompacted prior to the resumption of operations.
Bechtel. specification C-210 does not specifically include instructions for removal of frozen /
thawed compacted material upon resumption of work after winter periods.
g.
PSAR Amendment 3 indicates that cohesionless soil (sand) would be compacted to 85% relative density according to ASTM D-2049.
However, Bechtel specification C-210, Section 13.7.2 required cohesionless soil to be compacted to not less than 80%
relative density.
2.
10 CFR 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribed and accomplished.in accordance with documented instructions, procedures or drawings.
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CPCo Topical Report CPC-1-A Policy No. 5, Section 1.0 states, in part, that, " Instructions for controlling and performing activities affecting quality of equipment or operation during design, construction and operations phase of the nuclear power planc such as procurement, em
.s 3-Appendix A manufacturing, construction, installation, inspectien, testing
.. are decumented in instruction, procedures, sepcifications these documents provide qualitative and quantitive acceptance criteria for determining important activities have been satisf actorily accomplished.
. CPCo is committed to ANSI N45.2 - (1971), Section 6 which states, in part, " activities af fecting quality shall be ' prescribed by documented f
instructions,. procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings."
Contrary to the above, instructions provided to field
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construction for substituting lean concrete for Zone 2 material did not address the differing foundation properties which would result in differential settlement of 'the Diesel Generator Building.
b.
Also, contrary to the above, certain activites were not accom-plished according to instruction and procedures, in that:
(1)
The compaction criteria used for fill material was 20,000 f t-lbs (Bechtel modified proctor test) rather than a O
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compactive energy of.56,000 ft-lbs as specified in Bechtel Specification C-210, Section 13.7.
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Soils activites were not accomplished under the continuous supervision of a qualified soils engineer who would iL perform in-place density tests in the compacted fill to i
'i verify that all materials are placed and compacted !n accordance with specification. criteria.
This is required by Bechtel Specification C-501 as well as PSAR, Ammend-ment 3 (Dames and Moore Raport, page 16).
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. 10 CFR 50, Appendix B, Criterion X requires, in Part, that a pro' gram for inspection of activites affecting quality shall be establi,shed and executed to verify conformanco with the document 3d instruction, proce-a dures and drawings for accomplishing the activf.ty,
. CPCo Topical Report CPC-1-A Policy No. 10, Section 3.1, states, in l
part. that " work activities are accomplished accordind to approved prc edures or instructions which include inspection hold. points l
beyond which work does not proceed until the inspection is complete or written consent f:r bypassing the inspection has been received from the organization authorized to perform the inspections."
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-Appendix A l CPCo is committed to ANSI N45.2 (1971), which states, in part,
'!A program for inspection of activities af fecting quality shall i
be established and executed by or for the organization parforming i
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the activity to verify conformance to the documented instructions, j
procedures, and drawings f,r accomplishing the activity."
Contrary to the above, Quality Control Instruction C-1.02 the program for inspection of compacted backfill issued on October 18, 1976, did not' provide for inspection hold points to verify that soil work was satisfactorily acconplished according to doc'umented instructions.
4.-
10 CFR 50, Appendix B, Criterion XVI requires, in part', that measures sh' ail be' established to assure that conditions adverse to quality' such as failures, deficiencies, defective material and nonconformances l
are promptly identified and corrected.
In case of significant t-i conditions adverse'to quality, measures shall assure that corrective l
I 4: tion is teken to preclude repetition.
a CPCo Topical Report CPC-1-A Policy No. 16, Section 1.0 states, in I
" corrective action is that action taken to correct and preclude
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recurrence of significant conditions a4. _ se to the quality of. itens
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or operations. Corrective action includes an evaluation of the 1
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e conditions that led to a nonconformance, that disposition of the
.nonconformance and completions of the actions necessary to prevent or reduce the possibility of recurrence."
Contrary to the above, measures did not assure that soils conditions of' adverse quality were.promptly corrected to. preclude repetition.
For example:
9 a.
As of January 25, 1979, moisture control.in fill material had not been established nor adequate direction given to implement this specification requirement.
The finding that the field was not performing moisture control tests as required by specification C-210 was identified in Quality i
Action Request SD-40, dated July 22, 1977.
b.
Corrective action regarding nonconformance reports related to plant fill was insufficient or
' equate to preclude repeti-tion as evidenced by repeated deviations frcm specification i
i requirements. For example, nonconformance reports t{o. CPCo QF-29, QF-52, QF-68, QF-147, QF-174, QF-172 and QF-199 contain numerous examples of repeated nonconformances in the same areas of plant fill construction.
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UNITED STATES f
NUCLEAR REGULATORY COMMISSION
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6 Docket No. 50-329
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Docket No. 50-330 Consumers Power Company ATTS:
Mr. Stephen H. Howell Vice President 1945 k'est Parnall Road Japkson, MI 49201 Gentlemen:
This refers to the investigation conducted by Messrs. G. A. Phillip, E. G. Gallagher and G. F. Maxwell' of this of fice on Decemoer '11-13, 16-20, 1978, and January 4-5, 9-11 and 22-25, 1979, of activities at the Midland Nuclear Plant, L' nits 1 and 2, authorized by NRC Construc-tion Permits No. CPPR-81 and No. CPPR-82.
The investigation related to the settlement of the diesel generator building at Midland and the adequacy of the plant area fill. The preliminary results of this investigation were discussed with Consumers Power Company and Eechtel Corporation representatives in our office on February 23 and March 5.
1979.
The report on the matters discussed during those meetings were included with my letter to you dated March 15, 1979.
That letter also set forth the principal matters of our concern as a result of this investigation.
Enclosed is a copy of the report of this investigation.
In accordance with Section 2.790 of the NRC'r " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office within twenty days of your receipt of this notice, to withhold such information from public disclosure.
The application include a full statement of the raasons for which'the information must is considered _ proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
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i R 22 FM 2-Consumers Power Company
'the results of this investigation continue to be under rerian by the NRC staff. Upon completion of this review you will be advised of any enforcement action to be taken by the Cosmaission.
Should you have any questions concerning this investigation, we vould be pleased to discuss them with you.
Sincerely, l
James G. Keppler Director
Enclosure:
IE Investigation Reports No.. 50-329/78-20 and No. 50-330/78-20 cc w/eac1:
Central Files Reproduction Unit NRC 20b FDR local PDR NSIC TIC Ronald Callen, Michigan Public Service Countission Dr. Wayne E. North Myron M. Cherry, Chicago
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 050-329/78-20; 050-330/78-20 f
Subj ect :
Consumers Power Company Midland Nuclear Power Plant, Units 1 and 2 Midland, Michigan Settlement of the Diesel Generator Building Period of Investigation:
December 11-13, 18-20, 1978 and January 4-5, 9-11, 22-25, February 23, March 5, 1979
,8&Yk&As Investigators:
G. A. Phillip
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3-/3-73 E.
Gallag 1.
'),'er G. F. Maxwell
,7-/i-7Y 3-f[7f Reviewed By:
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Engi ering Support Section 1
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/7 F1 elli h
Reactor Construction and
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Engineering Support Branch Nf M
? [/'7 /7 7 C. E. Norelius Assistant to the Director 4
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3 4.
REASON FOR INVESTIGATION On September 7, 1978, Gie licensee notified Region III, by telephone, j
that the sectiement of the Diesel Generator Building and foundations experienced constituted a matter reportable under the requirements of 10 CFR 50.55(e).
k'ritten interim reports were subsequently submitted by the licensee by letters dated September 29 and November 7, 1978.
An inve'tigation was initiated to obtain information concerning the s
circumstances of this o'ecurrence to determine whether:
a breakdewn in the Quality Assurance program had occurred; the occurrence had been properly reported; and, whether the TSAR staterents were consistent with the design and construction of the plant.
SCOPE This investigation was performed to obtain information relating to design and construction activities affecting the Diesel Generator Building foundations and the activities involved in the identLfica-tion and reporting of unusual settlement of the building. The investigation consisted of an examination of pertinent records and.
procedures and interviews with personnel at the Midland site, the Consumers Power Company offices in Jackson, Michigan, and the Bechtel Power Corporation of fices in Ann Arbor, Michigan.
SUMMARY
OF FACTS By letter dated September 29, 1978, the licensee submitted a report as required by 10 CFR 50.55(e) concerning an unusal degree of settle -
ment of.the Diesel Generator Building (DUS).
This' report confirmed information provided during earlier telephone conversations on or about August 22, 1978, with the h*RC Resident Inspector and on September 7, 1978, with the Region III office.
This report was an interim report and was followed by periodic interim reports providing additional inferration concerning actions being taken to.ciolve the problem.
Further testing and monitoring programs and an evaluation of the resulting data have been undertaken by the licensee to determine the cause of the settlement and the adequacy of the corrective action being taken.
The results of t'r ese ef forts will be submitted in a final report to the NRC.
Information obtained during this investigation indicates:
(1) A lack of control and supervision of plant fill activities contributed to the inadequate compaction of foundation material; (2) corrective acti'on regarding nonconformances related to plant fill was insufficient or s.
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inadequate as evidenced by the repeated deviations from specification requirements; (3) certain design bases and construction specifications related to foundation type, material properties and compaction require-ments were not followed (4) there was a lack of clear direction and support between the contractors engineering office and construction site as well as within ene contractors engineering office: and, (5) the rSAF cont'ains inconsistent, incorrect and unsupported statements with respect to foundation type, soil properties and settlement values.
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t DETAILS f
i Persens Contacted During this investiFation approximately 50 individuals were contacted.
Twel've CPCo personnel which included corporate engineering and quality assurance personnel as well as site management quality assurance and quality control personnel.
Thirty-two Bechtel personnel were contacted.
These largely consisted of si'e engineering, quality assurance, quality t
control, survey and labor supervisors and personnel in project engineering, quality assurance and Geotech at the Ann Arbor, Michigan office.
Three individuals employed by U.S. Testing Company were also interviewed.
Introduction On August-22, 1978, the licensee informed the NRC Resident Inspector at the Midland site that unusual settlement of the Diesel Generator Building (DGB) had been detected through the established Foundation Data Survey program. While the licensee regarded the matter as s'erious it was notfconsidered to be reportable under the provisions of 10 CFR 50.55(e) until further data was obtained.
Following the acquisition of additional data from further surveys and a core boring' program which was initiated on August 25, 1978, the licensee concluded the matter was reportable a'nd so telephonically notified-Region III en September.7, 1978.
The notification was followed up by a series of interim reports the first of which was submitted to Region III by letter dated September 29, 1978.
Subse-quent interim reports were' transmitted by letters dated November 7, 1978 and January 5, 1979.
An inspection was conducted by Region III during the period October 24127, 1978, to review the data then available; to observe the current condition of the structure; and, to review. current activities., Information regarding
.the inspection is contained in NRC Inspection Report No. 50-329/75-12; 50-330/78-12.
On December 3-4, 1978, a meeting with NRR and Region III representatives u was held at the Midland site to review the status of the problem, to discuss open items identified in the aforementioned inspec' ion report t
ani possible corrective actions.
Identification and Reporting of Diesel Generator Building Sectiement Surveys to establish a baseline elevation for the DGB were t.ompleted by Bechtel on May 9, 1978.
As' a result Of these surveys, the Chief of Survey Parties noted what he considered to be unusual settlement. He
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indicated that from his~ experience he would have' expected about 1/8" settle-ment.- The July 22 data showed a differential settlement between various locat' ions ranging from 1/4" to a maximum.of 1 5/8".
He promptly instructed his survey personnel to resurvey to determine whether the data was accurate.
~ The resurvey. confirmed the accuracy of the survey dats.
The Chief of Survey Parties reportedLehe survey results to the 3echtel lead' civil field engineer. j l
- The lead civil' field engineer said that in. July 1978 the settlemen.
4 of a pedestal in the DGB was~noted from surveys and about a week later a 1" discrepancy was noted when scribes on' the DGB were being moved
- up. -He said that at that time he.was uncertain as to whether actus1 settlement had occurred, the survey was in error or the apparent discrepancy was a construction error. He instructed the Chief of Survey Parties to check.his survey results and to perform surveys more
?frequ, ntly than the 60-day intervals required by the survey prograe e
as a means of determining whether actual settlement had occurred and
.whether settlement continued.-
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The Field Project. Engineer was also informed of he apparent settlement and concurred with the lead civil field engineer's actions. He said he had toured the building at that time and he saw no visible indications
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of stress which could be expected when unusual settlement occurs.
The-lead civil field engineer said the DGB was monitored for about a month. -He compared the amount of settlement being experienced with the Lsettlement values reflected in Figure 2.5-48 of the FSAR and did not consider:it reportable until those values were exceeded. When the settlement did exceed those values as indicated by survey data obtained
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'on abe'ut August 118, 1978, he prepared a nonconformance report with
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- the assistance of. OC personnel.
- 3 ThefJuly 22 survey. data was transmitted by the site to the Bechtel Proj ec t Engineering of fice in Ann Arbor by a' routine transmittal memo '
dated July 26,'1978.
The data was received at Ann Arbor, processed through document control on' August 9, 1978, and was' routinely routed to the Civil Engineering Group Supervisor. He stated he did not review
-the data but placed a route slip on it indicating those members of his
?,roup who should review it.
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,The engineer in the Civil Group, who had established the survey prograe and who was' responsible for assuring it was being carried out, stated L
he reviewed the data and did not regard it as unusual.
For that reason 1:
he did not bring the matter to anyone's attention but merely routed l
it to other personnel in the civil group.
The engineer responsible for the DGB said he did not see the data before the settlement problee was identified by the field in a nonconformance report.
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1 With the issuance of the $oncomformance report, No. 1482, on August 18, 1978, CPCo was also informed of this condition.
On or about August 21,
,1978, the NRC Resident Inspector was orally informed of the matter by CPCo.
It was indicated at that time that although CPCo regarded the matter as serious, they did not consider it to be reportable under 10 CFR 50.55(e).
Construction on the DGB was placed on hold on August 23,1978 and a test boring program was initiated on August 25, 1978.
After prelir-inary evaluation of soil boring data, a Management Corrective A:tien Report (MCAR), No. 24, was issued by Bechtel on September.7, 1978.
The MCAR stated that based on a preliminary evaluation cf the data, the matter was reportable under 10 CFR 50.55(e), 1, iii and Regien I I was so notified by telephone on that date.
The telephone notification was subsequently followed up by a letter dated September 29, 1978, from CPCo enclosing a copy of MCAR 24 and Interim Report 1 prepared by Bechtel.
On the basis of the above, it is concluded that in this instance the l'icensee complied with the reporting requirements of 10 CFR 50.55(e).
Review of PS AR/TS AR Commitments en Compacted Fill Material In a previous NRC Inspection Report, No. 329/78-12; 330.78-12, an apparent inconsistency was identified between FSAR Table 2.5-14 (Su=ma'ry of Foundations Supporting Seismic Category I and II Structures),.
Table 2.5-9 (Minimum Compaction Criteria) and the site construction drawing C-45 (Class I Fill Material Areas) regarding the type cf foun-dation material to be used for plant area fill.
Table 2.5-14 identifies the supporting soil materials for the Auxiliary Building D, E, F, and G. Radwaste Building, Diesel Generator Building and Borated Water Storage Tanks to be " controlled compacted cohesive fill." Table 2.5-7 3
also indicates the soil type for " support of struct'res" to be clay.
u Contrary to these FSAR commitments, drawing C-45 indicates Zone 2 (random fill) material, defined in Table 2.5-10 as "any material free of humus, organic or other deleterious material," is to be used with "no restrictions on gradation." Boring samples substantiated that Zone 2 (random fill) caterial was in fact used.
During this investigation a review of documentation showed'that the commitment to use cohesive soils was also made in response to PSAR question 5.1.11 and submitted in PSAR Amendment 6, dated December 12, 1969, which states, " Soils above Elevation 605 will be cohesive soils in an engineered backfill." This response also indicated that certain class I components such as, emergency diesel generators, berated water storage tanks and hssociated piping and electrical conduit would be founded on this material.
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CPCd cuality assurance issued a nonconformance report QF-66, dated October 10, 1975, which stated that contrary to the PSAR statement (queced above) Specification C-211 being implemented at the site j
required cohesionles's (sand) material to be used within 3 feet of the walls of the plant area structures.
The corrective action taken was for Bechtel to issue SAR Change Notice No. 0097 which stated, "The TSAP vill clarify the use of cohesive and cohesionless soils for support of Class 1 structures." As noted above, the FSAR tables 2. 5-14 and 2.5-9 once again stated that cohesive (clay) material was used for support of structures while the construe. tion drawing continued to permit the use of-random fill material.
l This investigation included ef forts to ascertain whether procedures were established and implemented for the preparation, control and review of the technical criteria set forth in the safety analysis report (S AR).
This includei the role of both Bechtel and CPCo in the review of the SAR.
Bechtel had established control of the SAR in procedure MED 4.22 (Preparation and Centrol of Safety Analysis. Report Revision 1, dated June 20,197;).
The S AR preparation and review flow chart requires the Engineering Group Supervisor (EGS) to review the originator's draft for technical accuracy and compliance with the standard format guide.
Records indicated that Se: tion 2.5.4 was originated by the Bechtel Geetech group on January 3, 1977. It was reviewed and approved for technical accuracy by an engineer in the civil project group on April 29, 1977.
No technical inaccuracies were noted in the documentation.
The Civil EGS advised that he did not personally review.Section 2.5.4.
The designated engineer stated that in his review of the section he was primarily concerned with the Auxiliary Building not the Diesel Generator Building.
- de said the review of FSAR material was performed by members of a group set up for this purpose. Not all of the content i
was checked since they relied to some extent on the originator.
The author of Section 2.5.4 said he was not aware that changes regarding fill material had occurred since the' preparation of. the PSAR.
It was ascertained that Field Engineering did not review the FSAR prior to its submittal.
A par tial review of the FS AR revealed that although Figure 2.5-48 indicates anticipated settlement of the Diesel Generator Building during the life of the plant to be on the order of 3 inches.
Section 3.8.5.5 (Structural Acceptance Criteria) contains the following state-
" Settlements on shallow spread footings founded on compacted ment:
fills are estimated to be on the order of 1/2" or less."-
Section 3.8 was prepared by Project Engineering. Geotech, who prepared Section 2.5, said they were unaware of the presence of the statement regarding 1/2" settlement in Section 3.8.
The originator of Section 3.8 4
e
said that the above statement was taken from the Dames and Moore report submitted as part of the PS AR.
Since the PSAR did not show any change in this regard, he' assumed the statement was valid for inclusion in the FSAR. He said there was no other basis to support this statement.
CPCc also has an established procedure for the review and final appreval of the SAR by procedure MPPM-13 dated June 23, 1976.
Section 5.6-states that "CPCo shall approve all final draft sections of the FSAR prior to f
final printing." Discussion,with the responsible licensee representa-i tives for review of Section 2.5.4 indicated that a limited amount of cross-reference verification of technical content of the FSAR is j
performed by CPCo.
The CPCo Project Engineer in Jackson stated that the review of drawings and specifications was an owner's preference kind of thing.
No attempt was made to review all drawings and specifications since they did not have the manpower or expertise for that type of review.
The staff engineers of the various disciolines were asked to indicate the drawings and specifications they wanted to revieu.
.Regarding the review of the FSAR, he said that he had prepared a memorandum to the staff engineers stating the procedure that would be followed in performin: the review.
An examination of this memo, dated July 28, 1976, showed that prime reviewers would perform a technical review, resolve comments made by other reviewers and perform the CPCo licensing review to assure compliance with required FSAR format and content.
As portions of the TSAR were received from Bechtel, CPCo sent comments to BecF.tel.
Following this review, meetings between Bechtti and CPCo
' were held to clearup any unresolved matters before each section was released for printing.
A review of the files at CPCo relating to Section 2.5 and 3.8 showed that no comments were made concerning the above inconsistent and incorrect content. The apparent inconsistent and incorrect statements were not identified during the review of the FSAR prior to submittal and the review procedures did not provide any mechanism to identify apparent inconsistencies between sections of the FSAR.
Based on the above, measures did not assure that design basis included in design drawings and specifications were translated into the license application which resulted as an inconsistency between the design drawings and the FSAR.
This is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion III as identified in Appendix A.
(329/78-20-01; 330/78-20-01) s e
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Effect of Ground Vater in Plant Area Fill i
' Final plant grade will be established at elevation 634.
The normal ground water was' assumed to be at ground surface prior to construction, approximately elevation 603.
The surface of the water in the cooling water pond will be at a-maximum of approximately elevation 627.
The Dames and Moore report on Foundation Investigation submitted with PSAR Arendment No. 1, dated February 3, 1969, stated' chat, "The effect of raising the water level to elevation 625 in the reservoirs will cause the normal ground water level in the general plant area c.e eventuallv rise to approximately elevation 625. However, a' drainage q
system will be previded to maintain the ground water level in the plant I
fill at elevation 603."
A supplement to. Dames and Moore report was submitted in PSAR Acendment No. 3, dated August. 13, 1969, which changed the above planning of a drainage system to control the ground water.
The supplement states, "The underdrainage system considered in the initial report has been eliminated; consequently it is assumed that the ground water level in the plant area will rise concurrently to approximately elevation 625."
A Sechtel soils consult' ant theorized in a December 4, 1978, site cepting that if soils.beneath the diesel generator building had been cempacted toe _ dry'of optimum, changes in meisture after placement could cause the soils to settle significantly.
Therefore, the total effect of the ground. water being permitted to saturate the plant fill material is undetermined at this time.
An evaluation of this condition is under review by the licensee.
This item is considered unresolved.
(329/78-20-02; 330/78-20-02)-
i Review of Com; action Requirements for Plant Area Fill During the investigation a review of'the history of the compaction requirements was performed.in order to determine whether the compaction of the plant' fill was Laplemented in compliance with the commitments in the ?SAR and in site crr.struction specifications.
.PSAR, Amendment 1, dated February 3,1969, presented the Dames and Moore y
report " Foundation Investigation and Preliminary Exploration for Borrow Materials." The recommended minimum compaction criteria for support of critical structures is stated on page 15.
.It indicates 95% of maximum density for " cohesive soils" as determined by ASTM D-1557-66T and 100T for " granular soils."
PSAR, Amendment 3, dated Augu t 13, 1969, included a supplement to the Dames a'nd Moore report entitled, " Foundation Investigation and Preliminary
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Exploration for Borrow Materials." Page 16 of this report lists the recommended minimum compaction criteria for sand soils and cohesive soils.
For the fill material for supporting structures the minimum compaction is 85% relative density for sand and 100? of maximum density for clay as determined by ASTM D-698 modified to require 20,000 f t-lbs of coe; active energy'(equivalent to 957 of ASTM D-1557, Method D which provides 36,0'.0 ft-lbs of compactive energy).
Subsequent to the filing of Amendeent 3,
.no amendments were made to the PSAR to indicate that the reco=mendations contained in the Dames and Moore report would not be followed or w:uld be further modified.
Bechtel Specification C-210, Section 13.0 (Plant Area Backfill and Berm Backfill) indicates the compaction requirements for cohesive stil
( 13. 7.1) to be "not less than 95% of maximum density as determined b-,
ASTM D-1557, Method D" and f or cohesionless soils (sand) (13.7.2) to be compacted "to not less than 80% relative density as determined by ASTM D-2049."
.A comparison of the PSAR commitments to the specification requirements shows that the compaction commitments for cohesive soil (clay) were translated into the. construction. specification i.e. 95% of raxieur density using ASTM D-1557, Method D (compactive energy of 56,000 f t-lbs).
However, the compaction commitment in the PSAR for cohesionless soi,1 (sand) was not the same as in the construction specification, i.e. 555 relative density versus the 80; relative density, translated in the construction specification.
The compaction requirements actually implemented were as follows:
a.
Cohesive soil (clay):
957, of maximum density as decereined by.
~
the "Sechtel Modified Test," a compactive energy of 20,000 f t-lbs was used instead of 56,000 ft-lbs of compactive energy as committee to in the PSAR and required by the construction specification C-21c, Section 13.7.1.
b.
Cohesionless soil (sand):
807 relative densitv'as determined by ASTM D-2049 was used instead of 857 as committed.co in the PSAR. However, this is consistent with cot!struction specifi-cation C-210,~Section 13.7.2.
The compaction requirements implemented during construction of the plant area fill between elevations 603 and 634 were, therefore, less than the commitments made in the PSAR for cohesive and cohesionless fill material. In additon, the cohesive (clay) material was also compacted to less than that required by the Bechtel specification.
(Specification C-210, Section 13.7).
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A. review of Specification C-210 (specification controlling earthwork contract) beginning with Revision 2, dated July 27, 1973, which was issued for subcontract showed that it contained conflicting sections relating to the plant area backfill compaccion requirements.
Section 13.7, Compaccion Requirements, from revision 2 to the latest revision of specification C-210- consistently specified that the backfill in the plant area shall be compacted to 95% of maximum density as-deter-mined by ASTM 1557, Method D.
1 Section 13.4, Testing Plant Area Backfill, of specification C-210 cen-tained the statement that tests would be performed as set forth in Section 12.4.5, Laboratory Maximum Density and optimum Moisture cen:ent, which in turn specified a lesser standard, 20,000 foot-pounds per cu'ci:
f oot,,which is commonly ref erred to as the Bechtel Modified Proctor Density Test (BMP).
This is' contrary to the requirements of Section 13.7.
Section 12 of the specification applies to Dike and Railroad Erbankment Construction.
It was also noted that this control inconsistency.was reflected in the applicable Midland -QA Inspection Criteria, SC-1.10, Item 2.3(d) Compa: tion which statee "Eackfill material for the specified zones has been ccmpacted to the required density as detercined by Bechtel Modified Proctor Method" and ye: ref erences C-210, Section 13.7 as the inspection criteria.
The inconsistency in control is further indicated in Specification C-208 which ' defined the testing contract requirements of subgrade materials, Section 9.1.(Testing) required compaction tests to be in accordance with -
ASTM D-1557 and only when directed was the BMP compaction criteria to be used.
.It was determined contrary to this l'.S.
Testing was only orally advised that the BMP was the standard to be applied to the tests they performed of plant area fill.
-Through interviews and an examination of internal documents it was ascertained that because of these inconsistencies, the question of the applicable compaction secndard for cohesive materials in the plant area was a recurring one.
The following is a summary of the documentation regarding the confusien of the compaction requirements for plant area fill:
1.
Letter 7220-C-210-77 dated June 10, : 974, (subcontracts to Field Engineering) states "there has been some co., fusion as to the inter-pretaion of the following item:
13.7 Compaction Requirement: all backfill in the plant area and berm shall be compacted to not less than 957 of maximum density as determined by modified Proctor method 11 -
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(ASTM 1557, Method D), with the exception that Zones 4, LA, 5, 5A, and 6 Materials need no special compactive effort other than as described in Section 12.8.1 (emphasis included in specification).
Quality Control questioned whether the exception stated above applies only to Zones 4, 4A, 5, 5A, and 6 or did construction have to abide by Section 12.8.1 for Zones 1 and 2.
Section 12.8.1
. elearly requires Zone 2 caterial to be placed with a 50 ten rubber tired roller with a minimum of four roller passes per lift.
OC's interpretation was that the field needed "to obtain 957 of maxirur density by the modified. Proctor method (ASTM 1557, Method D), with no restrictions as to the method used to obtain these results."
2.
Letter 7220-C-210-23, dated June 24, 1974, (field Engineering to construction) responded to Item 1 above.
It states, "We have reviewed your June 10, 1974, IOM concerning compac.tive effort required on Zones 1 and 2 in the plant and berm backfill areas.
We agree with your interpretation; i.e. a 95? of maximum density is the acceptance criteria, and the number of roller passes listed in Paragraph 12.8.1 does not apply to plant and berm backfill.
We feel the specification is now clear and no FCR is required."
3.
Letter BCBE-370, dated July 25, 1974, (field construction to project engineering) lists outstanding itees requiring Project Engineering's action.
This includes the question, "Is the 95
compaction required in the plant area to be 95P of Bechtel Modified or 95% of ASTM-1557, Method D."
4 Letter BFBC-456, dated August 1, 1974, (Project Engineering to Field Construction) states that Geotech is addressing the questien posed in BCBE-370 (Item 3 above).
5.
Memorandum from Geotech to Bechtel Field, dated September 18, 1974, responds to the question raised in BCBE-370 (Item 3 above).
It states, "It is our opinion that all the compaction requirements that are needed for Zone II material in the plant fill is as stated in 13.7 with the exception that 7enes 4, 4A, 5, SA, and 6 materials need no special compactive ef fort other than described in Section 12.8.1."
Geotech reiterates the specification requirement of 957 of AS M 1557, Method D.
This I
was confirmed with the Geotech personnel.
6.
Telecon dated September 9,1974, from R. Grote (Field Engineering) to Rixford (Project Engineering) states, "I made an analogy (an exaggeration admittedly but applicable) that if the compaccion could be acheived with a2 herd of mules walking over the fill it would be acceptable as long as it got the required 95% compaction.
Rixford agreed."
12 -
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7.
Telecon Consumers to Bechtel Engineering dated September 19, 1974, expressed Consumers Power Company concern about what they felt was a lack of control of compaction in the plant area fill.
CPCo addressed the added responsibility this lack of control places on che inspector. Bechtel told CPCo that it "was the inspecter's i
job to make.sure we got proper placement, compaction, etc."
8.
Telecon dated September 18, 1974, by Bechtel Field Engineering to Bechtel Project Engineering discussed compaction requirements for specification C-210.
It* stated, " Compaction acceptance is based on meeting an 'end product' requirement, i.e. 95% of maximum density only. No method of achieving this 'end product' is specified er is required. Rixford fully agrees with the above."
9.
Telecen dated October 7,1977, from Bechtel Field Engineering to Bechtel Project Engineering states, "QA has asked for clarification of subject specification (C-210), Section 13 for plant area and berm backfill.
Section 13.4 for testing of materials refers to Section 12.a and therefore, requires the Bechtel Modified Proctor Density Test for Compaction of cohesive backfill.
Section 13.7 for ecmpac-tion of' the same materials refers to testing ir accordance with ASTM D-1557, Method D Proctor, without specific reference to Bechtel Modification." Bechtel. Engineering responded to this question.as follows:
"This apparent conflict is clarified by Specification C-208, Section-9.1.a, direction to the testing subcontractor, which calls for ASTM D 1557 test for these materials and also allows Bechtel Field (the contractor) to call for the Bechtel Modification of that< test. ~Either method is therefore acceptable to project engineering."
10.
Telecon dated October 7,1977, from Bechtel QA to Bechtel Project Engineering questions, "Is the intent of Paragraph 13.7 of Speci-fication C-210 that the test be.run to the 'Bechtel' codified proctor test as is indicated in the FSAR Parag'raph 2.5.4.5.3 and in response to NCR 88."
Engineering's response was "yes."
Various interviews were held with Bechtel construction field engineers, U. S. Testing personnel and Bechtel Ann Arbor Geotech and Project Engineering personnel to ascertain their understanding of the compaction y requirements.
Four predominant versions of the understood compaction requirements were stated by various individuals within the'Bechtel organization.
They are as follows:
Specification C-210 required the contractor to perform a.
compaction to the ASTM 1557, Method D, however, the testing requirements would be performed to the less stringent "Bechtel Modified' Test Method."
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b.
The required compaction and testing was always understood to be based on the "Bechtel Modified Test Method."
The required compaction and testing was always understood to be c.
' based'on the standard ASTM 1557, Method D requirements.
- d.
A tacit understanding had been established to use the Bechtel
' Modified Method, but to exceed this requirement by enough to also satisfy the requirement of ASTM 1557, Method D.
It is apparent from the above four distinctly different understandings of-the compaction requirements, that the apparent confusien was net reselved. A member of the Bechtel QA staff in Ar.n Arbor who had previously been a QA Engineer at the Midland site said that QA audits of QC, inspection' criteria.did not identify the above inconsistencies.
This failure to accomplish activities affecting the. quality of the plant area fill in accordance with procedures is considered an item of nencem-pliance with 10 CFR 50, Appendix B, Criterion V as identified in Appendix A.
(329/78-20-03; 33.0/78-20-03)
Review of Moisture Control Requirements for plant Area Fill Specification C-210, Section 13.6 (Moisture Control) requires moisture control of the plant area fill material to' conform.to Section.12.6.
.The moisture control requirement in Section 12.6.1 sta tes, in part,
" Zone ~1,.1A and 2 material which require moisture control, shall
.be moisture conditioned in the borrow areas," and that " water content during compaccion shall not be more than two percentage points
~
below optimum moisture content' and shall not.be more than two percen -
tage points.above optimum moisture content."
~ Contrary to the above, Bechtel QA ide.ntified in SD-40 dated July 22, 1977, that "the field does not take moisture control tests prior to i
and during placement of the ' backfill, but rather rely on the moisture results taken from the in-place soil density tests."'
The following is a summary of the documentation that followed the identification of the above deviation from specification C-210.
1.
Letter BCBE-1533R (dated August 15, 1977) field to project engineering states, "it was'found that densities meeting specification require-ments could be attained, irrespective of the use of' moisture tests," and that " moisture tests were not used to control backfill moisture." The field requested "that project engineering agree to acceptance of backfill materials installed in the past, along with
- the records thereof, irrespective of the use of the moisture cests."
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30, 1977) responsed to the fields
- 2.
Letter BEBC-1859. (dated September
', requestfin BCBE-1533R.
Engineering states, "It should be noted
--that:it is-ideal to control the moisture of backfill material at the-borrow areas by conditioning" and that "the procedure used'to.
take moisture content tests af ter compaction would not have direct-impact on the quality of werk."
Engineering then agreed with the
- field request ~ that " backfill placed prior to modification of testing
'methodsLeo be accepted as is."
- 3..
Telecen October. 10,1977, (Bechtel QA Site to Bechtel Engineering, Ann Arbor) indicated that,~"there are no moisture-requirements a:
)
the time'of density testing, only density requirement.
The cois urt requirement.is prior to compaction."
4.
Telecon Ci ober 13, 1977, (Bechtel Engineering to.Bechtel OA Site) changed what was indicated in the telecon on October 10, 1977, (Item 3 above).
Engineering then stated, "The moisture require-ment- (+ 2% of optimum) is mandatory and must be implemented at the time of placement and testing." This is contrary to what was stated on October 10, 1977.
5.
Letter BCBE-1669R (dated November 18, 1977) once again is a field request to Bechtel engineering requesting, " written clari,-
fication of the 2*. tolerance on backfill moisture content during compaction."
6.
Letter BEBC-1998 (dated December 15, 1977) provides engineering's response to BCBI-1669R requesting clarification of the moisture requirement.
Engineering stated, "The moisture content of the soil I
should be within 2% of optimum during placement and compaction..
However, this property of the soil is not necessarily a measure of its adequacy,after compaction."
7.
. Letter 0-1631 (dated December 21', 1977) closes 0A Action Request S~
SD-40 (dated July 22, 1977) which first identified the moisture control deficiency.
8.
Telecon (dated April 7,1978) from Field Engineering and Ouality Control to Project Engineering once again requests them "to clarify,
BEBC-1998".(December 15, 1977), Item 6 above.
Two situations were i
presented to engineering as follows:
(a) The moisture sacple
[
taken from the borrow area at the start of the shift is acceptable, 2.
however, the moisture test taken in conjunction with the density test f ails while compaction was attained; and (b) The moisture sample taken from the borrow area at the start of the shift fails and the material is conditioned to meet moisture content requi ed, i
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however, the moisture test later fails at the time the passing compaction test is taken.
Engineering responded, "the above two situations are. acceptable as is."
This response is contrary te the direction previously given in telecen dated October 13, 1977 (see Item 4 above).
9.
Letter GLR-249 (April 16, 1978) is a Bechtel Site QA request to Project Engineering to resolve the moisture content situation and "to provide clear direction for the control of moisture content." QA recommends "one possible solution would be to delete the requirement to control the moisture content and rely on the ccmpaction requirement only for completion of soils work."
10.
Letter SEBC-2286 (June 1, 1978) was Project Engineering's response to GLR-249 (Item 9 above).
It states, " moisture content is not necessarily a measure of a soil's adequacy to act as a foundation or backfill material," and that " soil with the specified density following compaction would not be rejected on the basis that its moisture content was not controlled in the borrow area."
Based on the' reviews of documentation, moisture control had not been implemented as the specification required.
In addition, the matter had not been resolved for the period of time frem the issuance of CA Action Request SD-40 on July 22, 1977, until June, 1978, during which time soils safety-related work continued.
According to the licensee, although moisture control was not strictly followed in accordance with specification requirements, final density tests were used as a basis for acceptance of soil placement.
As pointed out to the licensee, moisture control is a required contrel point to assure attainment of percent compaction specified in specifi-cation C-210.
4 This failure to assure that conditions adverse to quality are promptly I
identified and corrected to preclude repetition is c6nsidered an item j
of noncompliance with 10 CFR 50, Appendix B, Criterion XVI as 4.dentified in Appendix A.
(329/78-20-04; 330/78-20-04)
I a
Review of Subgrade Preparation for Plant Area Fill l
The Dames and Moore report on foundation investigation submitted with l
PS AR Amendment 3, dated A 13, 1969, states, "the clay soils are susceptible to loss of s.
geh due to frost action, disturbance and/or the presence of water.
If the construction schedule requires that foundation excavation be left open during the winter, it is recommended that excavation operations be performed such that at least l
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3 1/2 feet of natural, soil or similar cover remain in place over the final subgrade or overlying the mud mat.
This layer of protective material is necessary to prevent the softening and disturbance of subgrade soils due to frost action." The licensee indicated that instructions for winter protection of foundation excavations were trans-mitted by sketch C-271.
The Dames and Moore report also stated, "If filling and backfilling operations are discontinued during periods of cold weather, it is recommended that alltfrozen s' oils be removed or recompacted prior to the resumption of operations."
AfterreviewoftheapplicablesectionsofspecificationC-210ki.e.
Sections 12.5.1, 12.10, 10.1 and 11) the inspector has determined that the Bechtel specification did not provide specific instructions for
-removal or recompaction of frozen / thawed soils upon resumption of work after the winter period to preclude the effects of frost action on the compacted subgrade materials.
This failure to assure that regulatory commitments as specified in the l'icense application are translated into specification, drawings or
-(
instructions-is :ensidered an item of noncompliance with 10 CFR 50, Appendix B, Criterion III.
(329/78-20-05; 330/78-20-05)
Review of Nonconformance Reports Identified for Plant Area Fill The following exaeples of nonconformance and audit reports regarding the. plant area fill were reviewed relative to the cause of the noncon-formance and the engineering evaluation and corrective action:
No.
Nonconformine Condition Engineering Evaluation (1)
CPCo Failure to perform inspec-
"Use as is" based on QF-29 tion and testing of'struc-samp1'es taken from stock (10/14/74) tural backfill (sand) pile.
delivered to jobsite 29 of 30 day in Aug. and Sept.
74.
Bechtel QC not informed of deliveries.
(2)
CPCo Ibisture control out of Accepted in place material QF-52 tolerance of specifica-with low moisture.
(8/7/75) tion C-210, Section 13.6.
(3)
CPCo Compaction test had been Failing tests were cleared QF-68 calculated using incor-by subsequent passing (10/17/75) rect maximum lab density.
- cests, j
Test recorded as passing i
was actually a failure.
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(4)
.Bechtel Material placed did not Engineering stated that NCR 421 meet moisture require-
- this ramp area is temp-(5/5/76) ments.
orary_and would be removed.
This was removed based. on note added to NCR 421 on 3/18/77.
- Note: ' In the vicinity of this ramp a Geotech engineer deter-mined the material to be " soft" and directed a test pit to be dug for investigation in September 1978 af ter the D. G. Bldg.
settlement was identified.
(5)
CPCo Lift thickness exceeded Material was remcved and QF-120 maximum of 4" in areas recompacted.
(9/21/76)-
not accessible to roller equipment.
Insufficient monitoring of placing crews.
Laborer foreman not familiar'with re-quirements.
(6)
CPCo Inspection plan C-210-4, Corrected inspection plan QF-130 Rev. O, permits 12" lift requirements.
(10/18/76) thickness for' areas in-accessibic to rollers caused by "misinterpre-
+
tation of specification requirements.
Spec. per-mitted 4" lift thickness.
(7)
CPCo Failure to perform inspec-Engineering accepted the QF-147 tion and testing of struc-
=aterial in place "use (2/2/77) tural backfill (sand) on as is."
12/1/76, 12/14/76 and 1/11/77 (same as QF-29 l
dated 10/14/74) material i
lacked gradation test requirements.
'(8)
'CPCo Moisture control out-of-Engineering accepted QF-172 tolerance and compaction materials.
(7/8/77) criteria not met.
(9)
CPCo Gradation requirements Engineering accepted QF-174 for Zone 1 materials not materials.
(7/15/77) met.
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CPCo' Moisture content not met;-
Issued Bechtel NCR's No.
QF-199 compaction' requirements 1004 and 1005; No. 1004 (11/4/77) for. cohesive and' cohesion-still open; No. 1005
~
less' soil not met.
Mater-
" accepted as is."
ials had been accepted-using incorrect testing data.
(11)
CPCo Gradation recuirement not' Engineering " accepted 2
QF-203 met yet materials accepted, as is."
(11/22/77)
(12)
CPCo Meisture content require-Bechtel QC to infore Audit ments not met; test fre-foreman directing soils
,T-77-21 quency not met, work of. requirements.
(5/77 &
6/77)
(13)
CPCo Compaction requirement for Proj ect Engineering to Audit'
.both cohesive and cohesion-justify the materials.
T-77-32 less materials not met; these failing tests (10/3/77) moisture requirements not represent.
NCR QF-195 met; cests had been accept-still open.
ed yet failed requirements.
(lai Bechtel Same deficiency as NCR 698.
Accepted, "use as is."
XCR 686 (2/1/77)
(15)
Bechtel Structural backfill (sand)
Engineering accepted NCR 698 was delivered without "use as is."
(2/9/77) acceptance tests on Oct.
26, 29, Nov. 12, 197.6 and Jan. 11, 12, 1977.
(16)
Bechtel Moisture content require-
" Accepted as is" based on NCR 1005 ments not met.
density test only.
(10/26/77)
Based on a review of the above nonconformance and audit reports correc-tive action regarding nonconformances related to plant fil1 was insuffi-cient or inadequate as evidenced by the repeated deviations from speci-t f.' cation requirements.
This failure to assure that the cause of conditions adverse to quality are identified and that adequate corrective action be taken to preclude D
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s repetition is considered an item of noncompliance with 10 CFR 50, Appendix E, Criterion XVI as identified in Appendix A.
(329/78-20-06; 330/70-20-06)
Review of Calculations of Settlement for Plant Area A review of the settlement calculations for the structures in the plant area was performed during a visit to the Bechtel, Ann Arbor Engineering office.
Specific attention was given to structures founded on plant area " compacted fill." The following specific findings were made:
1.
FSAR, Section 3.8.4.1.2 (Diesel Generator Building) indicates the foundation of the DGS te be continuous footings with inde-pendent pedestals for each of the Diesel Generators.
Contrary to the structural arrangement described in the FSAR, the settle-i ment calculations for the DGB were performed on the premise that the building and equipment loads would be uniform 1v distributed to the foundation material by a 154' x 70' ' foundation mat.
The settlement calculations were performed between August 1976 and October 1976 by Techtel Geotech Division.
Discussion with the Geotech Engineer who performed the settlement calculations indicated that he had not been informed of the design change of the foundation until late August 1978 when the excessive settlements of the DGB and pedestal became apparent.
2.
FSAR Tigure 2.5-47 indicates the load intensity for the DGB to be
~
4 KSF (4000 lbs. per sq. f t.); however, the settlement calculations reviewed indicate a uniform load of 3 KSF (3000 PST).
This appears to be a conflict between the FS AR and settlement calculations.
3.
The settlement calculations for the berated water storage tanks were performed assue.ing a 54' diameter circular foundation mat with an assumed uniform load of 2500 PSF.
Ins'tead, the tanks are supported on a continuous circular spread footing and compacted structural backfill as detailed on the construction drawings.
The Geotech engineer was also not made aware of the revised foundation detail.
,8 FSAR Figure 2,5-48 (Estimated Ultimate Suttlements) indicates the anticipated ultimate settlement for Unit I and 2 plant s t r'uc tur e s.
The values indicated for the Diesel Generator Building and Berated Water Storage Tanks are the values developed assuming uniformly distributed loads fouettd on mat foundations as was indicated in the settlement calculatiars reviewed even thrugh the actual design and construction utilizes spread footings.
The FSAR does not indicate the foundation e
o.
c) type assumed in the settlement calculations and therefore the values in the.FSAR figure appear to represent the settlements estimated for the
- l s
as-constructed spread footing foundation.
4.
During a review of the settlement calculations, it was observed that the compression index (C ) for'the compacted fill between c
' elevations 603-and 634 in the plant area was assumed to be 0.00; (estimate. based on experience).
FSAR Section 2.5.4.10.3.3 (Soil Parameters) indicates the soil compressibility parameters used in the settlement calculation'are presented in Table 2.5-16.
This table. indicates'that for the plant fill elevations 603 to i
634, the compression index used was 0.003.
Contrary to the FSAs
-value, 0.001 was used.in the settlement calculations reviewed.
This value is directly used to determine the estimated ultimate sectiement of structure supported by plant fill material.
Based on the above examples, reasures did not assure that specific design bases, included in design documents, were translated into the license application resulting in inconsistencies between design docu-ments and the FSAR.
This is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion III as identified in Appendix A.
(329/78-20-07; 330/78-20-07)
Discussions with CPCo personnel responsible for the technical ~ review and format indicated that a comparison between the design documents and FSAR had not been performed. Likewise, Bechtel personnel indi-cated that a detailed comparison for the technical accuracy of design
. documents to the FSAR statements had not been performed; instead
~
r'eliance was placed on the originator's input.
According to the Civil Engineering Group Supervisor, a cat foundation was c'onsidered for the DGB only during the conceptual stage.
All drawings generated shew a spread foot.ing foundation.
Thet supervisor stated that the Geotech engineer apparently based his calculations on
'the conceptual stage information. He went on to say that an individual in Geotech was responsible for checking the calculations and the first thing he is supposed to do is detereine that the basis for the caleu-lations is correct. He said that apparently this was not done.
Review of Settlement of Administration Building Footings During the investigation, it was disclosed that the Administration Building at the Midland Site had experienced excessive settlement of the foundation footings.
Although the Administration Building is a non-safety-related structure,-it is supported by plant area fill material compacted and tested to the same requirements as material
~.
s.
O i
i
s supporting safety-telated structures 3nd therefore pertinent to the
. cur. rent settlements b?ir.g experienced oy the Diesel Generator Building.
The following are the events relating to the settlement of the Admini-stration Building fo'otings.
During the end of August, 1977, a Bechtel field engineer observed a gap between a slab and the grade beam of the Administration Building.
On j
August 23, 1977,. a survey was taken of the settlement.
The results indicated that the footings supporting the grade beam had experienced settlement ranging from 1.32" (north side) to 3.48" (south side).
This settlement took place between July 1977, and the end of Augurt 1977.
The footings were supported by " random fill" (Zone 2 material).
The concrete footings on the order of 7' 6" by 7' 6" by l' 9" deep were removed along with the grade beam.
The random fill material was also removed.
According to C. 5. Testing personnel, it was observed during excavation of the fill material that there were voids of 1/4" to 2" or 3" within the fill and these were associated with large lumps of unbroken clay measuring up to 3 feet in diaceter.
The Civil Field E'ngineer assigned responsibility for plant fill verk said that, although he was no soils expert, it was his opinion that the problem was caused by the presence of pockets of water due to drainage from the-steam tunnel.
The Lead Civil Field Engineer also indicated a drainage problem caused the Administration Building footings settle-ment.
They v-'
however, unclear as to how the water pockets were
~
formed, i.e.
- her they were formed as the fill was being placed or how they coulu develop after the fill was compacted.
The excavated fill was replaced with concrete and the design of individual foetings was changed to a continuous spread footing f
design for support of the building.
As a result of the settlement of the'Adninistration Building footings a total of seven borings were taken of which five were in the Admini-stration Building area, one in the Evaporator Building area and one south of the' Diesel Ggnerator Building.
In the Administration Building area the foundation material was found to be " soft" with " spongy char-acteristics." The two other borings did not indicate unusual material h
properties.in that the blow countJ were reasonable.
These borings were taken in September 1977.
The licensee indicated that reports from Bechtel concluded that the primary cause of the settlement in the Administration Building area was insufficient compaction o( the fill.
Bechtel also concluded that
" deviations from specific compaction requirements was the result of
.g 22 -
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s
~.
j' repeated erroneous ~ selection _of coupaction standard," i.e. the inectreet j
O ' optimum moisture-density curve was used for the soil material being i
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. compacted. In'effect, the moisture-density curve was erroneously assu-ed to' represent the soil being used and therefore soil was compacted to less than maximum' density.
1 Bechtel, personnel,' including the' Civil Group Supervisor, Proj ect
- Engineering, the Field Project Engineer, the Lead Civil Field FnF neer, i
and the' Chief Civil QC Inspector all stated that the Administratien i
~ Building footing settlement was regarded as a localized proble.
The Lquestion as to the: adequacy of the entire plant area fill alc not arise i
even1though the following similarities existed between the Adeinis::atien Building area and rest of plant fill; (a) same soil specification arplied.
(2) same_ material-(random fill) was used and (3) same control procedures
=and selection'of laboratory compaction standards was used.
The Diesel Generator; Building area required even more fill than other safety-related structures'since its base is located at a higher elevation than the etners.
Review of Interface Between Diesel Generator Building Foundation and Electrical Duct Banks A review of the design interface between the electrical and civil secticns of the Bechtel organization was performed to determine whether the design' accounted for the interaction of the' electrical duct banks and spread footings on the differential settlement of the northside of the DGB. It was determined that the electrical and civil groups made
' accormadations in the _ design to permit settlement of the spread fectings areund the electrical duct banks by including a styrofoam " bond breaker" around ene duct banks.
Both electrical and civil groups reviewed and approved electrical Drawing E-502 which includes the appropriate detail.
However-Bechtel-Drawing C-45 which 1.dentifies Class I fill caterial g
areas permits the use of Zone 2 (random fill) which includes "any material' free of humus, organic or other deleterious raterial." This.
-in'effect.'does not preclude the use of concrete arodnd the electrical duct banks beneath the spread footings.
Due to the difficulty in cor-pacting, Bechtel elected to replace the soil material with concrete.
Letter f rom proj ect engineering to field construction, dated Decerber 27,,
1974,-states, " lean concrete backfill is considered acceptable for replacement of Zone 1 and 2."
The instruction is considered inadequate, n
in that, the concrete placed around the duct banks restricted the settlement on the north side of the DGB where electrical' duct banks enter through the footing.
This contributed to the excessive differ-ential settlement in the ; ort 5-South direction across the building.
i.
r s..,
r
'This failure to prescribe adequate' instructions for activities affecting the quality of safety-related structures is considered an item of noncor-pliance with 10 CFR,50, Appendix B, Criterio'.. V as identified in Appendix A.--(329/78-20-07; 330/78-20-07)
Review of Soils Placement and Inspection Activities for Plant Area ~111 A subcontractor, Canonie Construction Company, South Haven, Michigan, performed the major portion of -the earthwork at the Midland site.
Although Canonie was primarily engaged to construct the cooling pond dike,.they also performed most of the plant area fill work.
- Bechtel, however, also performed plant fill. work prior to and after Cancnie left the site in cid-October 1977. The last Canonie daily QA/QC fill
. placement report is dated; 0ctober 16, 1977.
According to Canonie 'QA/QC. records the first fill in the DGB area was placed in late October and early November 1975. No further fill was placed in the trea until July 1976.
After that tiee, fill work in the area was interspersed with soils. work in other areas.
k'hile it would be dif ficult to identify the soil work performed by Bechtel versus that performed by Canonie, records reviewed indicated that most-of the Bechtel work was done'during the latter part of 19,76 and continued through 1977 and 1978..Although most of the Bechtel werk related'to placing sand _arcund piping and ducts after they were laid
- and placing sand adjacent to walls, some motorized work compacting clay fill was also done by Bechtel.
Regarding the plant. fill work performed by Bechtel, CPCo Audit Report -
No. T-77-21 dated June 10, 1977, identified a number of deficiencies which recommended the corrective action to be as follows:
(1) "the foremen directing the soils work should be instructed as to the required moisture content limits" and (2) "the foreman directing the soils work should be instructed as to the correct test frequency requirements." Interviews with two such Bechtel foremen confirmed the fact that they were directing soil operations.
They indi:sted they received their instruction regarding 'lif t thicknesses and testing requirements verbally from field engineering through a general foreman.
I Bechtel design criteria C-501 (Page 8) and PSAR Amendment No. 3 (Dames and Moore Report, Page 16) states that, " Filling operations should be performed under the _ continuous technical supervision of a qualified soils engineer who would perform in-place density tests in the coepacted fill to verify that all materials are placed and compacted in accordance with the recommended criteria."
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e Based on the above, the soils activities were not accomplished under the continuous technical supervision in accordance with Bechtel design cri-teria. This failure to provide a qualified soils engineer to perfore technical supervisio'n for activities affecting quality as required by specifications and the PSAR is considered an item of Soncompliance with 10 CFR 50, Append *x B, Criterion V.
(329/78-20-08; 330/78-20-08)
The foremen indicated that Bechtel Field Engineers and QC inspectors were rarely in the areas where soils activities were going on.
The foremen decided when and where tests were taken.
The locations of tests were approximated by pacing or visually estimating distances from columns or building walls.
Lift thicknesses were determined visually, usually without the use of grade stakes.
Soils testing services are provided by U. S. Testing Company based on the rsquirements of Specification C-208.
The two U. S. Testing tech-nicians who said they performed an estimated 90% of the soil testing during the' years 1975-77 indicated that they rarely saw a Bechtel field engineer or QC inspector in the areas where plant fill activities were going on.
One technician said he could recall only one occasion when a QC inspector was present when he took an in-place density test.
The other technician estimated he had contact with a QC inspector in the field about once a month.
A Bechtel OC inspector, however, was ass,igned to the testing laboratory on a full-time basis.
U.S. Testing personnel stated that erroneous test locations were p chronic problem regarding the Bechtel placed fill.
The location of
- a test was usually given at the time of the test by a labor foreman or a laborer if the foreman wasn't there.
Sometimes, however, a foreman was not familiar with the area in which he was working and the locatien was not provided until sometime after the test.
It became necessary on-occasion to withhold test results as a means of getting the test location.
Test elevations were approximated sequentially.
The technicians further advised that rarely did a Bechtal QC inspector request a test.
Normally, labor foremen requested them.
On occasion a technician passing through an area would be asked by a foreman if a test should be taken. Upon completion of in-place tests, the results were usually coemunicated to the foreman directing the work.
Test failures were also reported by telephone to QC or Field Engineering.
A weekly report of test was provided to Bechtel QC and Field Engineering who reviewed any test failures and resolved them.
U. S. Testing personnel advised that they were requested to take tests of clay fill while it was raining and in order to do so, plastic was held over them to protect their equipment while the test was made.
Even though it was raining, the fill placement work was not stopped on I
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s some occasions.
A Bechtel foreman confirmed that density tests were on occasion taken while it was raining.
While this is not contrary to the specification instructions, it is contrary to standard practice.
U. S. Testing personnel indicated that when moisture was added, the procedure did not include blending the material which resulted in mushy seams.
It is commonly accepted good parctice to disc the fill af ter spraying it with water to add needed moisture.
A Bechtel fere an stated that if moisture was needed they compacted 6" then sprinkled it and then added another 6".
The field engineer who was assigned responsibility for plant fill werk stated he did not spend full cine on soils work since he also had responsibility for two structures, the steam tunnel and general yard work. He said he tried to get out to the area where fi.11 work was being done once a da.
Some times he did and sometimes he did not.
He indicated it was his impression that the QC Inspector responsible for the soils work on the day shift visited those work areas once or twice a week. He confirmed that only oral instructions were furnished to the foremen whom he felt were conscientious.
The main problem he experienced wich'the foreman was maintaining proper lif t thickness.
The QC inspector who was primarily responsible for the plant fill work is no longer empicyed by Bechtel.
The QC inspector who was respons'ible for the plant fill work on the night shift stated that he tried to devote about one hour a night to the plant fill activities.
He indicated that during 1976-1977 there was much emphasis being placed on cadwelding and rebar work and it was necessary to spend the majority of his time on those activities. He maintained that.he did have f airly f requent contacts with the technicians who performed the in-place density tests, partic-ularly when test failures occurred.
He indicated it was his impression that the labor foremen were directing fill placement adequately.
4 Review of Inspection procedures The following procedures which are relative to backfill operations at Midland Units 1 and 2 between August 1974 through December 1977 were reviewed.
I a.
Bechtel Master Proj ect QC Instruction for Compacted Backfill -
C-1.02 was issued for construction October 18, 1976,.and it is presently the current instruction which is used by Bechtel QC (when Bechtel is the inspection agency, providing first level inspections during backfill operations).
Further, this instruc-tion was used by Bechtel QC when monitoring the activities of t
26 -
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d other inspection agencies (Canonie) when such agencies were performing the first level inspections of backfill operations during the ' time periods of October 18, 1976, until June 28, 1977, b.
Bechtel Quality Control Master Inspection plan for Plant Poundation Excavation and Cooling Pond Dikes (Plant Area Backfill and Berz
. Backfill) - Procedure No. C-210-4 was the instruction utilized by Bechtel QC when monitoring the activities of other inspection agencies that were providing the first level inspections'of b.:k-fill operations (this instruction was utilized during time periods prior to October 18, 1976).
Bechtel Quality Control Master Inspection Plan for Structural c.
Backfill Placement - No. C-211-1 is an instruction utilized by Bechtel QC when performing first level inspection of backfill activities prior to October 18, 1976.
Bechtel Procedure C-1.02, listed above, was written as a replacement for both Procedures C-210-4 and C-211-1.
The inspection activities which were delineated in Procedures C-210-4 and C-211-1 were compared with those described in Procedure C-1.02.
The following are some of those activities which were compared:
Inspection Code for--
Activities / Task Description C-210-4 C-211-1 C-1.02 Backfill Material
(*)
.l.
Free of brush, roots, sod, I
S(V).
snow, ice or frozen soil.
(*)
2.
Material moisture conditioned S
I S(V) to required moisture content.
3.
Structural backfill used I
with 3" of plant structure, shall be cohesionless and free-draining.
(*)
4.
Material not placed upon I
S(V) frozen surface.
5.
Foundation approved prior to H
H R/H backfill placement.
Priortostartofwbrk, area I(V) 6.
free of debris, trash and unsuitable material.
9 27 -
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t Compaction Requirements u
1.
Cohesionless material com-S S
S(V) preted not less than 80*
relative density.
j
(*)* 2.
Cohesive material compacted W
S S(V) to not less than 95% max.
density.
(*)
3.
Zones 1,.1 A, 2 and 3 material W
I S(V) in uncompacted lifts not ex-ceeding 12"; areas not access-ible.to roller equipment the material placed in unccmpacted lif ts no exceeding 4".
Material Testing 1.
Verify testing and test results are as 'per engineering requirements.
a.
Materials S
S S(V) b.
Moisture S
S S(V) 6.
Compaction S
S S(V) 2.
Review lab test report verifying:
a.
Proper test method.
R R
R
~
b.
Proper test frequency.
R R
R y
c.
Technical adequacy.
R R
R I - Inspection point H - Hold point W - Witness point S - Surveillance (V) - visual R - Review records Those activities identified by an (*) asterisk indicate inspection require-ments which have been relaxed from the original procedural requirements.
It is considered that the relaxation of actions relating to the confir-mation that' soils ' placement activities were conducted according t'e 1
28 -
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specifications contributed to inadequate compaction of foundation and fill ma,terial and the increase incidence of deviations from specifications m
regarding lift thickness, moisture control and frequency of testing.
This f ailure to provide adequate inspection of activities af fecting quality is considered an item of noncempliance with 10 CFR 50, Appendix B, Criterion X.
.(392/78-20-09; 330/78-20-09)
F.xii.Me e t in g s Members of the NRC staff cet with Consumers Power Company and Bechtel Corporation at the NRC Region III of fice on February 23, 1979 to present the scepe, purpose, and preliminary findings of the investigation.
That meeting was subsequently followed by a second meeting held on March 5, 1979, during which Consumers Power Company responded to,the preliminary investigation findings.
The documents used during these meetings were transmitted to Consumers Power Company by NRC letter dated March 15, 1979.
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g 4r UNITED 5TATES y
4, NUCLE AR REGULATORY COMMISSION
,j WASHINGTON. D. C. 20$65
.c l v
j Jt!N 131979
{
Docket No. 50-329/330 MEMORANDUM FOR: Dudley Thompson, Executive Officer for Operations Support. IE FROM:
M:rold D. Thornburg, Director Division of Reactor Construction Inspection, IE
SUBJECT:
COMMENTS ON RIII ENFORCEMENT PACKAGE ON MIDLAND j
SETTLEMENT PROBLEMS DATED APRIL 3, 1979 l'
lI We have reviewed the above referenced package which uncer J. Davis's memorandum of March 21, 1979 was forwarded to XOOS as the responsible coordinating group within IE. These coments are provided to be con-j sistent with this memorandum and the follow-up memorandum you provided to your enforcement personnel also on March 21, 1979.
i' In sumary, it is our opinion that four of the five false statements identified by the Region will probably be substantiated to be material false statements and that they were made in careless disregarc of the
. facts. Therefore', it would follow that there weald prooably be four o.
instances of a material false statement each of which would have a civil penalty of $5,000 imposed for it. The fifth item is not, in our opinion, a material false statement.
.,j
-The enclosure presents our detailed recomendatios.s or, this matter.
IT you have questions please contact us.
f.
ft.V1 M 1L M.d Harold D. Thornburg, Directcr
. Division of Reactor Construction 9
I Inspection, IE
Enclosure:
Coments on' Midland
- Enforcement Package l
CONTACT:
R. E. Shewmaker, IE 49-27551 h050$ 00N
x
(
j
_ u._=...,... : ;..
l.
COMMENTS ON MIDLAND ENFORCEMENT PACKAGE TRANSMITTED TO THORNBURG FROM KEP.PLER, DATED 4/3/79 f
-t 1.
The material false statement items (probably 4) should be put into an Appendix A entitled, " Notice of Violation " and will be those items with a civil penalty. An Appendix B entitled, " Notice of Proposed Imposition i
of Civil Penalties" should be prepared. The other items of noncompliance
~
should be 6ddressed in an Appendix C, " Notice of Violation." "
2.
All' statements quoted from the SAR in'the citations should be clearly identified by amendment-number and/or revision number and date.
3.
A check of Statement 1 regarding fill and backfill placement shows it
.,p.S is apparently from the original version of the FSAR.
Revision 1,11/22/77 i,
has a different statement and is the current version.
Some of the other hp+[- statements referenced have been revised now after the investigation. T g
must be reexamined.
If.the statements quoted in the RIII draft can be utilized in an enforcement action then we judge the statement to be a material false statement.
In reaching this conclusion we note that there is a need to. quote or provide a copy of the text from construction drawings C-45 stating that Zone 2 material is to be used as Class I fill if the citation is to be properly supported.
- a. Y h 4.
Statement #2 can probably be classed as a material false statement if e cNo N the results'of the interview with the cognizant engineer and/or the calcu-
' v 5+ M lation sheet prove that 3.0 ksf was used in the settlement calculations.
5.
Statement #3 is viewed to be a ' material false statement, but there is g
a need to fully document what was.actually done in the execution of the
~ 4 ',d calculations. Again a copy of the calculation sheet and/or a statement of the cognizant engineer is needed to properly support the finding.
6.
Statement #4 can probably be classed as a material false statement H
- $n if the results of the interview and/or the calculations are provided to i
support the finding.
7.
Statement #5 is judged to not be a material false statement. This is due to the fact that the statement quoted is written as a predicted future value for settlement.
I 8.
For those statements which will become material false statements with a civil penalty, remove them from the draft Appendix A and move the remainder to the new Appendix C.
9.
All statements judged to be material false statements must be examined to see in what " state of mind" or in what circumstances the licensee made
~
the statement. This is relevant to the question of " civil penalty" vs.
"second chance." In our judgment these instances appear to be situations of " careless disregard" of the facts which would warrant civil penalty.
.. ~
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V Y:
2 JUN 131979
,1 t-f cc w/ enclosure:
E.
J. G. Keppler, RIf.
$C D. W. Hayes, RIII-L./"--
l T. W. Brockett, X005 t.
G. W. Reinmuth, RCI h..
R. E. Shewmaker, RCI F
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