ML20126L864

Forwards Summary of Ofc of Nuclear Reactor Regulation Comments on Keppler 790403 Memo Re Backfill Deficiency

ML20126L864
Person / Time
Site:	Midland
Issue date:	08/09/1979
From:	Hood D Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20126L803	List: ML20126L799 ML20126L806 ML20126L819 ML20126L822 ML20126L828 ML20126L834 ML20126L838 ML20126L843 ML20126L848 ML20126L854 ML20126L859 ML20126L864 ML20126L873 ML20126L879 ML20126L885 ML20126L887
References
NUDOCS 8106090704
Download: ML20126L864 (4)

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'#"*%3, UNITED STATES Attachment 17

-8 o NUCLEAR REGULATORY COMMISSION

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5 .p WASHINGTON, D. C. 20555

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AUG 91979 MEMORANDUM FOR: File FROM:' Darl Hood, Project Manager, Light Water Reactors Branch l No. 4, DPM j i

SUBJECT:

NRR CO MENTS REGARDING ENFORCEMENT ACTION ON. MIDLAND S0IL DEFICIENCIES An April 3,1979 memorandum from J. Keppler to H. Thornburg identified five statements from the FSAR regarding the backfill deficiency at the Midland site which I&E considered to be false, and requested a determination as to the materiality of these statements. Following receipt of this memorandum by NRR on May 7, 1979, it was distributed to technical review branches for review and.a meeting was held August 1 to provide NRR comments.

Meeting attendees, listed by Enclosure 1, included both I&E and OELD. A sumary of the NRR coments as to the materiality of the five same-numbered statements of the Keppler memo is given in Enclosure 2.

OELD defined " materiality" of FSAR statements. This definition served as the

~ basis for judgments in the meeting. A statement was deemed to be " material"

'if, not withstanding the fact that-it was detected by the I&E investigation, it would or could have an influence upon a safety conclusion of the NRR staff

-(i.e., if it could have resulted in an improper finding or less probing analysis by the staff). The technical significance and willfullness of any such false statement is relevant to selection of the specific enforcement action deemed to be appropriate.

It was noted that some of the technical reviewers had not yet completed review I

of some of the relevant background material, and therefore only preliminary coments could be given at the meeting. A subsequent meeting on or about August 3,1979 was scheduled to confirm or modify these preliminary coments.

'y;...w l'/, O Darl S. Hoo Project Manager Light Water Reactors Branch No. 4 Division of Project Management

Enclosures:

As stated cc: See next page 8106090 %

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cc: All Attendees G. Gower L. Rubenstein S. Varga D. Vassallo W. Olmstead H. Thornburg J. Keppler W. Haass D. Skovholt J. Murray

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1-ENCLOSURE 1 ATTENDEES August 1, 1979 R. Shewmaker (I&EHQ)'.

T. Brockett (I&E HQ)-

D. Gillen NRR GSB)

J. Lieberman OELD)

D. Bachman OELD)

D. Hood NRROPM)

L. Heller NRR GSB)

J. Gilray NRR QAB).

J. Spraul NRR QAB)

J. Knight NRRAD:Eng)

P. Baci I&E HQ)'

R. Lipinski {

.F. Schauer NRRSEB)(part-time)

NRR SEB)

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C. Moon NRR LWR #4: Acting BC)

R. Jackson NRR GSB: Chief) 1

e ENCLOSURE 2 NRR COMMENTS ON APRIL 3,1979 XEPPLER MEMORANDUM

1. This statement is considered by NRR to be material; the fact that the Midland fill is of the wrong type (random fill verses structural fill) and was not sufficiently compacted is viewed by NRR as the core of the settlement problem. Other findings in the report appear to be subparts of (contributers to) this central problem and NRR suggested consideration be given to combining all five findings.

2. NRR stated that the difference between use of 3.0 KSF and 4.0 KSF for the load density for the Diesel Ger.arator Building calculation would not or did not influence a safety conclusion by the NRR staff, and therefore, was not considered to be " material". Rather, the finding is viewed as an indicator of poor QA performance.

3. NRR stated that the difference between use of 0.001 and 0.003 for the index of compressibility for the Diesel Generator Building calculation would not or did not infuence a safety conclusion oy the NRR staff, and therefore, was not considered to be " material." Rather, the finding is viewed as an indicator of poor QA performance.

4. NRR recognizes the statements in FSAR sections 2.5.4.10.3.5 and 3.8.4.1.2 regarding the type of mat for the Diesel Generator Building to be inconsistent. However they are not false insofar as they reflect what was actually done. In its review, NRR interpretated the use of 41 points to represent a mat foundation, whereas FSAR section 3.8.4.1.2 accurately ~

identified the buidling to have continuous footings. The improper calculation is viewed by NRR as an indicator of poor QA perfor-mance.

5. This statement is considered to be a subpart of statement 1. It also appears to be relevant to poor QA performance.

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