ML20210S469

Advises Not to Do Any Housecleaning of Paperwork Re Zack,Due to Interrogatories & Document Production Pending

ML20210S469
Person / Time
Site:	Midland, 05000000
Issue date:	03/13/1984
From:	Wilcove M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Danielson D, Hawkins F, Spessard R NRC
Shared Package
ML20150F172	List: ML20150F170 ML20150F806 ML20151B319 ML20151B324 ML20151B345 ML20151B447 ML20151C503 ML20151G694 ML20209B290 ML20209B331 ML20209B400 ML20209B407 ML20209B413 ML20209B419 ML20209B517 ML20210S413 ML20210S451 ML20210S469
References
FOIA-84-96 NUDOCS 8610080145
Download: ML20210S469 (78)

Text

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h March 13, 1984 Note to: THOSE ON ATTACHED LIST From: Michael N. Wilcove, OELD

SUBJECT:

ZACK INSPECTION FOR MIDLAND In the hearings for Midland we have contentions addressing problems with work done at Midland by Zack.

In September 1982, Intervenor Mary Sinclair filed a request for interroga-tories and document production pertaining to Zack. For those of you who may not be aware, interrogatories are questions that must be answered under oath. Document production requires parties to go through their. files and produce papemork that is relevant to the request (similar to a FOIA request).

Since inspections and investigations were undemay, the Board postponed the request.

This note is to advise you not to do any housecleaning of paperwork pertaining to Zack. This includes personal notes, drafts, telephone logs, and any other writings that deal with the Zack inspection. We will not have to necessarily turn the paperwork over but we will have to acknowledge its existence and maybe show it to the Board to decide whether it has to be turned over. Of course during the course of the inspection, notes, drafts, etc. may have been created and discarded. However, no further housecleaning should be done.

I will be in touch with you at a later date to determine when we have to comply with the discovery request.

In the meantime, please feel free to contact me if you have any questions (492-8666).

Also, I would appreciate your checking the attached list. If there is anyone not on the list who has Zack paperwork,' please pass this note to that persan and/or inform me."~

Of course, if you have no such documentation, please disregard this notice.

Thank you for your help.

8610090145 860926 Michael N. Wilcove -

PDR FOIA Counsel for NRC Staff RICE 84-96 PDR

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Implementation of Ren,edial Soils Work

a. Introduction [4

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1. The "0M" session of these hearings was convened to assess, among other things, the adequacy. of quality assurance implementation for remedial soils work. Accordingly, we examine with great care both steps that CPC has taken to properly implement quality assurance for the reme-dial soils work and the quality of the work being performed. The latter is um coinly of greater consequence than the former. No matter how im-pressive a program may sound, the program amounts to nothing if it does not result in successful implementation of the work.

2. At the outset ..we distinguish between difficulties of a techni-cal nature and problems with quality assurance implementation. Unless they reflect deficiencies in quality assurance, we do not at this time weigh technical difficulties against CPC. We have already determined the remedial fixes to be technically sound. Hence, we would only consider technical concerns if they were of such significance that the record would have to be reopened on the adequacy of the remedial measures.

Nothing we have heard has reached that level.1/

1/ Twice, Intervenor Barbara Stamiris requested that the record be reopened on the technical adequacy of the remedial fixes. Both motions were denied. Consumers Power Company (Midland Plant, Units 1 and 2), LBP-83-50, 18 NRC 242 (1983); Tr. 22676.

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b. Implemer_tation of Remedial Soils Work Through Approximately July 1982 5 )

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. b(1). Examples of improper implementation of remedial soils work

3. When Mr. Keppler testified in the summer of 1981, he expressed reasonable assurance that CPC would properly implement quality assurance for remedial soils work. It is undisputed however, that Mr. Keppler's -

hopes were not met. In April 1982 Mr. R. Ccok expressed his view to Mr. Keppler that CPC's performance in remedial soils work had not risen above the " Category III" rating that SALP II had given. (KepplerOctober testimony pp. 1-2). Mr. J. Cook and Mr. Mooney concede that .in the first half of 1982, CPC was encountering difficulties in implementing remedial soils work. (Mooney Testimony, p. 3. J. Cook Testimony, p. 4, see also Tr. - 17120-21) .

4. The drilling incidents described below reflect difficulties CPC encountered in properly implementing quality assurance for remedial soils work. See 5 to infra. See also Keppler October 1982 testimony, Attachment B, p. 7 (1 15). -

5. The record also shows various other difficulties with remedial soils work the CPC encountered in the first part of 1982. Since the existence of such difficulties is undisputed, we only need to outline them. One inspection report found that adequate procedures had not been developed for (1) work on the auxiliary building access shaft, ;

(2) control of specification design changes, (3) permanent dewatering wells and (4) implementation of overinspection plans. (Inspection O

Report 82-05, Itidland Section October testimony, Attachment a, Notice of Violation, pp. 1-2, Details of Inspection Report, pp. 3-6). I ;

i 2] Inspection Report 82-05 also cited CPC with a deviation for failing to have a qualified civil staff. Notice of Deviation, Details of Inspection Report pp. 2-3. This will be discussed at 9 to infra.

Another report cited CPC with a severity IV level violation due to problems with slope layback at the auxiliary building access shaft. In particular this violation consisted of two noncompliances. The slope layback was being constructed at a steeper degree than specified by the design drawing. That was the first noncompliance. When it was discovered, a field chadhe request was written up instead of a nonconformance report. That was the second noncompliance. (Inspection Report 82-18, Midland Section October testimony, Attachment 5, Notice of Violation, Details of Inspection Report, pp. 4-5, Keppler October Testimony, Attachment B, t 9, Bird Testimony pp.1-31, Tr.14,381-85,19,193-96.19,282-92,19,310-13).E 3] Inspection Report 82-18 also cites CPC with a Severity Level IV violation for not using qualified procedures to calibrate crack -

grouting equipment used for the Borated Water Storage Tank. (Notice of Violation pp. 2-3, Details of Inspection Report pp. 5-6). Subse-quently, upon receiving CPC's response explaining why proper proce-dures were in place, the Staff reclassified the noncompliance as an open item pending submission of further information. CPC has sub-mitted the information, but the Staff had not at the time of the hearings reviewed it. (Bird testimony, pp. 4-5, Tr. 19,181-83, CPC Exhibit 50). That being so, we do not weigh this open item adversely against CPC.

6. We also note that SALP III lists noncompliances, both-severity Level IV and V, and deviations documented in Inspections Reports 82-03

and 82-11, also issued in the first half of 1982. (StaffExhibit24, pp.5-6). [,

b(2). Alleged examples of poor soils work not weighed.

. against CPC

• / . Two examples offered by the Staff of poor implementation of such work during the first part of 1982 we decline to weigh adversely against CPC.

8. The first involved a question as to the drilling method to be used on temporary construction dewatering well ME-55 between the turbine and diesel generator building. In mid-June, 1982, CPC began setting up to drill tt.e well using the rotary drilling method. Upon seeing this, Dr. Landsman informed CPC that the Staff had not approved the rotary drilling method for the well. (Wheeler, prep. test, p. 2). The Staff believed that had CPC not been stopped from drilling, the April 30, 1982 order would have been violated. (Keppler October 1982 testimony, _

Attachment B, i 11(c)).

9. Mr. Wheeler explained why CPC believed the rotary method was acceptable for drilling ME-55. In March 1982 CPC submitted and received approval for procedures for drilling service water pump structure wells.

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In its submittal, CPC specified that the rotary drilling method would be used for those wells. Auxiliary building wells were also being drilled.

A specific method of drilling had apparently never been delineated for au% .%

those wells. However, seventy-two of seventy-si wells had been drilled using the rotary method. (T r. 18,788-89) . " O 9 J ' 'M

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10. Furthermore, after the issuance of the April 30, 1982 0rder, CPC and the Staff corresponded to assess the scope of work already

approved by the Staff. In flay 19, 1982 CPC submitted a letter to the Staff delineating what work they understood to have already been approved by the Staff. (Staff Exhibit 26, Attachment 3). On fiay 25, 1982, the Staff responded (Staff Exhibit 26, Attachment 4). The Staff indicated k & c . ~,

that drilling of servue "Mer h"mn (tructure wells was approved on a case by case basis. (Id., Enclosure 6). Neither the May 10 nor the May 25, 1982 letter discusses the drilling method to be used for *

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a dewatering wells.

11. On May 26, 1982, CPC asked the Staff for permission to drill additional auxiliary building dewatering wells, including ME-55.

(Tr. 18789-90). The Staff agreed. (Wheeler, pp. 2-3, Tr. 18790, 18810).

12. Based on the Staff's approval to drill ME-55 along with the Staff's approval of the rotary method for service water pump structure wells and the ' fact that previous temporary auxiliary building wells had been drilled using the rotary method, CPC believed it to be acceptable to use the rotary method for ME-55. (Wheeler, p.2, Tr. 18,789-90).

13. In mid-June 1982, CPC and Dr. Landsman reviewed the May 25, 1982 letter. They determined that the May 25, 1982 letter was unclear as to what drilling method should be utilized. (Tr. 18791) . -

14. To clear up the confusion, Mr. Kane was contacted. Mr. Kane stated that the cable tool method of drilling should be used. (Wheeler,

p. 3).

15. After talking with fir. Kane, CPC issued a stcp work order.

(M. Tr.18793).O .

16. On June 25, 1982 at a Staff audit CPC confirmed that rotary drilling was acceptable for auxiliary building construction wells. (Jd.

Tr. 18,791). -

-4/ It seeais clear that the stop work was issued on June 11, 1982.

(Tr. 18,791). The record, however, is confusing as to whether Dr. Landsman expressed his concern over the rotary method on June 10 or June 11, 1982. (Compare Wheeler p. 2, Tr. 18,791, 18,793, ano 18,796). We do not consider this discrepancy to be of consequence.

Similarly, it is unclear and also immaterial, precisely what day Mr. Kane was called.

17. We find that there was confusion on both the Staff and CPC's parts as to which method was the proper one for drilling ME-55. We also find that CPC acted reasonably to clear up the confusion.

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18. Another issue which we decline to weigh against CPC concerns Applicant's determination to continue excavation in the vicinity of the FIVP prior to the resolution of concerns over adequacy of the supports for the FIVP.

19. The supports had originally been installed "non-Q" in 1971.

(Tr. 18,555). In mid-1982, however, the Staff requested CPC to produce documentation showing that the supports were built according to the drawings. Since CPC was unable to do so, it agreed to inspect the -

supports, flineteen deficiencies were discovered, but were ultimately dispositioned use as is. (Staff Exhibit 26, Attachment 11, pp. 8-9, Wheeler pp. 4-5, Tr. 18,858-59).

20. Since CPC's inspection of the support system revealed deficien- l

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cies, the Staff insisted that the FIVP be load tested and inspe,cted once again. ( T r. 18,878-79 ) .*

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• The FIVP had been load tested in 1981, but without Q procedures.

See 5 to supra. The load test being requested in mid-1982 was a second one. .

21. Subsequer.tly, CPC informed the Staff that the supports had to be further modified to increase the margin of safety. In particular, additional rock bolts, brackets and supports for the FIVP slabs were to be put in. (Staff Exhibit 26, Attachment 11, p. 9, Wheeler, p. 4, Tr.18,900-01).

23. The Staff was displeased that CPC wished to continue excavation in the vicinity of the F_IVP before the additional modifications were completed and the supports were finally checked out. (Keppler October 1982 Testimony, Attachment B % 14, Staff Exhibit 26, Attachment 11, p. 9 Tr.18,878-89).

24. CPC indicated to the Staff that due to schedule pressures it was unwilling to halt excavation pending modification and assessment of the FIVP supports. (Keppler October 1982 Testimony, Attachment B,114.)

We would be troubled by CPC's concern over schedule if it were shown that quality was being sacrificed for schedule.

25. In this case, CPC offered an acceptable explanation for con-tinuing excavation before the assessment of the supports was complete.

As long as an excavation did not go directly under the FIVPs, it could be safely done before the supports for the FIVPs were fully checked out.

The Staff ultimately agreed. (Wheeler, p. 5). ,

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b(3). Conc 1csion with respect to implementation of remedial soil 3 work through approximately July 1982

27. WhilesomeinstancesdiscusseddonotweighagainstChC,we find that during the first part of 1982, CPC was not successfully imple-menting quality assurance for remedial soils work.

c. Steps taken to improve remedial soils work, May through September 1982 _

28. In the spring and summer of 1982, CPC and the Staff, both together and separately,._took steps to respond to problems CPC was having in implementing quality assurance, the steps taken had to do with both remedial soils work and balance of plant work. While there is overlap, this section focuses primarily on remedial soils work. Steps taken to deal with balance of plant work are discussed at 5 to , infra.

28a. In May 1982, CPC initiated the excavation permit system described at 5 to infra.

29. Perhaps the most significant step taken is the work authoriza-tion procedure, dated August 11, 1982. (Keppler October 1982 testimony, -

Attachment H). CPC and the Staff jointly developed the procedure. The Work Authorization Procedure was in response to the violation of our April 30, 1982 Order discussed at 5_ to _ infra (Mooney, p. 4, Tr. 14,614-15).

30. Pursuant to the procedure, CPC submits to the Staff monthly lists of soils work activities to be implemented in the next sixty days.

The Staff then decides which work on the list is' critical and which is

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not. fion-critical work may proceed. Critical work may only proceed after the Staff gives CPC written authorization to do the work.; (Keppler October 1982 testimony, Attachment H). The role of the work authoriza-tion procedure in permitting remedial soils work to continue is discussed at 5 to infra.

31. Around the same time, CPC reorganized itself in the hopes of being better able to implement the remedial soils work. Both MPQAD and the project divisions were reorganized.

31a. The project divisions were reorganized into a unified project organization for remedial soils work. Mr Mooney is the single point of accountability for the s. oils work. Subgroups responsible for remedial groups all report to fir. Mooney. Before, the various subgroups reported to different individuals, either in CPC or Bechtel. ' O'4 sd OM

32. Also, in August 1982, the soils section of fiPQAD was reorganized to provide single point accountability for work covered by the April 30, 1982 Order. Of particular significance is the fact that CPC took over from Bechtel the QC function in the soils area. (Wells, pp. 3-4).

34. The Staff favors the MPQAD takeover of the QC soils function.

In fact, the Midland section had specifically recommnended such a take-over. (Keppler October 1982 testimony, Attachment D, Enclosure 3).

Mr. Keppler viewed the takeover as positive (Tr. 15,579).

33. Additionally, the changes in both the project organization and in liPQAD were designed to bring a higher level of management pr.esence directly to the site. (Mooney, p. 17).

35. As part of its takeover of the QC function, CPC committed to retrain and recertify soils QC personnel. The certification inyolves threeareas,(1)programmaticqualityprocedures(programmaticguality plans, nonconformance procedures, general quality procedures)

(2) inspection plans (inspection requirements, inspection methodologies, testing methodology, hold points, etc.) and (3) on the job training followed by a performance demonstration. (Mooney, p.16).

36. On August 26, 1982, Staff management called a meeting with CPC management. The purpose was for Mr. Eisenbut and Mr. Keppler to express to CPC its concern over the problems CPC was having in building the plant properly. (Tr. 15,197)... Staff management did discuss with CPC various reconnendations that the Staff had developed for setting CPC on the right track for building the plant properly, e.g., third party reviews, augmented Staff inspections, MPQAD takeover of the QC function. However, t

the discussions of Staff recommendations was general. (Tr. 15,190-911) .

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Rather, Staff management told CPC to come back with its own plan for improving its performance. (Tr. 15,197 ) .

37. A week later, on September 2,1982, CPC showed fir. Keppler a draft of its program. Mr. Keppler however found the outline lacking in it.acs detail. (Tr. 96f10BA). On September 17, 1982, CPC came back with two letters containing proposals for improving quality assurance at Midland.

One addressed of plant work. The other addressed remedial soils work.

(Keppler October 1982 testimony, Attachments E & F, respectively.) The balance of plant letter will be addressed at i to infra.

The remedial soils letter is addressed below.

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38. The remedial soils letter offered the following seven steps for improving CPC's performance of remedial soils work.5/  ;

(1)- Retaining a third party to independently assess the implementation of the auxiliary building underpin-ning work; (i _ to _ ) 6/

(2) Integrating the soils QA and QC function under the direction of MPQAD; (3) Creating a " Soils" project organization with dedi-cated employees and single-point accountability to accomplish all work covered by the ASLB order; (i ___

to _ )

--5/ These steps had been the making prior to the issuance of the September 17, 1982 letters. For example, CPC announced the creation of its new soils organization at the August 26, 1982 meeting described above. (Tr. 15,195). Also, Stone & Webster arrived onsite on September 20, 1982, three days after the remeidal soils letter was issued. (Tr. 17,247).

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The first six items were discussed during the hearings. The findings addressing the items are noted.

(4) Estab.lishing new and upgraded training activities, including a special quality indoctrination program, specific training in underpinning activities, and the use of a mock-up test pit for underpinning con-struction training; (5_ to _)

(5) Developing a quality improvement program (QIP),

specifically for soils remedial work; (i ___ to ___)

(6) Increasing senior management involvement in the -

soils remedial project through weekly, onsite man-agement meetings wherein both work progress and quality activities are reviewed; (5 ___ to ___)

(7) Improving systems for tracking of and accounting for design connitnents.

The Staff found the approach taken in the September 17 soils letter to be acceptable (Tr. 15,257).

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d. Retraining Recertification of Soils QC inspectors; _

training of soils pro.iect personnel  :

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41. In late September 1982, the liidland Section visited the site to witness the recertification necessary for the f1PQAD takeover of the soils QC function. The Staff found the retraining program to be unacceptable.

(Midland Section October Testimony, pp. 1-2). In particular, MPQAD exam-iners during oral examination repeated questions so as to give the examinee several attempts t'o correct wrong answers. Also, during the oral examination, examiners marked as "non-applicable", relevant, but incorrectly answered, quhstions. Furthermore, the oral examinations lacked the technical content necessary to properly measure the examinee's comprehension of the activity for what he or she was being tested. (Mid-land Section March 1983 testimony, Attachment Ib, Details Section p. 3). ,

Finally, the Project Quality Control Instructions (PQCI's) were not prop-erly controlled. (Id. p. 3 Notice of Violation).

42. As a result of CPC's poor execution of retraining and recerti-fication of soils QC inspectors, CPC committed to stop all remedial soils work except for certain preventative maintenance activities, stop all examinations for soils requalifications, decertify all soils QC personnel previously certified, retrain QC personnel who fail the recertification examinations and develop a written examination for all remedial soils QC recertification. (Id. Details Section, p. 3, Midland Section October 1982 testimony,Attachmentla).2/ I e

e 7/ CPC's poor performance in retraining and recertifying QC s6ils in-spectors led to concerns about, and actions taken with respect to, balance of plant work. See 1 _ to _ infra.

43. Since that time, CPC has been retraining and recertifying soils QC personnel. They receive fomal training and must pass closed book examinations on both the QC program and on specific inspection plans.

Also, the inspectors must undergo field performance demonstrations for each inspection plan. (Wells, prep. test, p. 5).

44 As of April 1983, the Staff had not followed up on its September 1982 inspection of the retraining and recertification of soils QC inspectors. (Tr. 14,486). However, the Staff did find some problems with the retraining and recertification process for balance of plant QC

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inspectors. (i _ to _ infra). However, since we are satisfied with the way CPC handled the problems, we do not weigh those balance of plant difficulties against CPC as we examine the retraining and recertification process for soils QC personnel.

44a. In the fall of 1982, the Staff examined the training process for remedial soils project workers. The inspectors reviewed a quality assurance indoctrination session given by CPC. They found inadequate -

documentation of who had attended the session and who needed to do so.

Also reviewed were specific training procedures given by subcontractors Mergentine and Spencer, White and Prentis (SW&P). For these procedures, there was no documentation of training for craft foremen and craft workmen. Also, CPC was not providing any training in emergency;proce-dures. (Midland Section March 1983 testimony, Attachment la. (Details,

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kkg ga pp. 2-3) Finally,nprototype test put was examined and found tu ce-in need &5 modification. (Id.)  :

45. In January 1983, the Staff returned to the site to foilow up on, their review of the training process. Except for the need to expand some of the flergentine training, the Staff found that CPC had met the Staff's concerns. (flidland Section March 1983 testimony, Attachment Ic, Details Section 1, p. 3).

e. The DGB inspection as it relates to remedial soils work

46. Also in the fall of 1982, the Diesel Generator Building inspec-tion took place. Since that inspection concentrated on balance of plant work we address it in greater detail at 1 to infra.  !!e do note however that the DGB inspection revealed a significant breakdown in qual-ity assurance for balance of plant work. In addition, the inspectors, during the DGB inspection, noted that armor stone for a perimeter dike had not been either purchased or installed pursuant to "Q" requirements.

(Keppler March testimony, Attachne'nt 4, Details Section, p. 28; Attachment 3,p.6).

f. Permitting actual excavation to begin

47. Despite all the problems CPC had with properly implementing

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remedial soils work and the findings of the DGB inspection, the Staff permitted CPC on December 9,1982, to begin actual excavation work. In particular, the Staff authorized certain work relating to the drift, excavation and installation of piers W12 and E12 under the turbine building. (Keppler March 1983 testimony, p.3). Prior to that .only preliminary work had been authorized. fir. Keppler explained in detail

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the rationale for penaitting excavation to begin. (See5 to ,

supra.) .

48. The Midland Section agreed with Mr. Keppler that CPC's perfor-mance on its initial excavation was satisfactory. Except for a few con-cerns, Dr. Landsman found that CPC was adequately implementing the excavation. (Keppler March 1983 testimony, Attachment D to Attachment 1). Dr. Landsman further testified that there has been no problem with CPC's performance of underpinning work that warranted Staff halting of the work. (Midland Section March 1983 testimony, p. 5, Tr. 14,628 ) . Yet, apparently due to certain problems discussed below, Dr. Landsman did feel th,at the situation may have been getting close to warranting a shutdown. (Tr. 16,551).

g. Problems with implementation of remedial soils work from the end of November 1982 through the first half of 1983

49. Although the Staff viewed CPC's performance in excavating for piers W12 and E12 as satisfactory and does not believe any difficulties encountered by CPC have warranted a holding of underpinning, there were problems from the end of December 1982 through the first half of 1983.

50. For instance, in late 1982, the Midland Section found l

inadequate the packages CPC was sending to the Staff for approval pursuant to the Work Authorization Procedure. CPC was asking the Staff to approve work on the premise that Staff concerns would be incorporated during the work itself (Midland Section March 1983 testimony, 1 Attachment ic, Details Section, p. 4, Tr. 14,617). Since then, the

problem has been resolved by requiring CPC to assert, upon submitting the package, that all work is ready to begin. (Tr. 14,617 ) .  ;

51. In the winter of 1983, Mr. R. Cook was dissatisfied with the manner in which Bechtel and its subcontractor, Wiss Janney, were recording data during the jacking of the FIVP. More specifically, they were intending to record the data only five minutes after release of the jacks and then stop recording. Mr. R. Cook believed that Wiss Janney should have waited at least an hour before taking the data.

(Tr. 14,636-14,640). The procedures called for taking data within an hour after releasing the jacks. (Tr. 14,637). Accordingly, Bechtel and Wiss Janney were apparently not violating the procedures. Assuming the procedures were being followed, it is clear from Mr. R. Cook's testimony that he believed that taking data only five minutes after receiving the jacks was poor technical judgment. CPC apparently agreed. (Tr. 14,640).

In any event, Bechtel did accommodate Mr. R. Cook's concerns by waiting another hour to take more data. Also, the procedures have been revised to correct this problem. (Id.)

52. In April,1982, CPC encountered quality assurance difficulties as it did a load test on Pier 11 at the auxiliary building.8/ During the -

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CPC also ran into problems of a technical nature. See IP to , infra. Additionally, at S to , supra. We discuss the Staff's concern over a lack of communicativeness about potential problems with the load test.

week of ~ April 18, 1982, CPC found a minor problem with the Project Quali-ty Control Instruction (PQCI) for the pier. Two PQCI's, one for pouring the pier and the other for the Carlson meters, were written in such a way

s that neither could be closed before tne other was closed. The problem was to be rectified by modification of the PQCI for the Carlson; meters.

In particular, the old PQCI had to be closed out and a new one ssued.

CPC determined the problem to be solved and informed the Staff that all quality assurance problems with respect to the load test had been resolved. Subsequently, CPC did a " top-to-bottom" review of all docu-mentation associated with the pier. Finding no problems, it began the test. (Tr. 17,179-17,184 ) .

53. Unfortunately, neither the review done by CPC before advising the Staff that there were no problems nor the review afterwards were wholly successful. Approximately ten days after the test began, a prob-lem was found. In closing the old PQCI and issuing a new one, the in-formation was improperly transferred by the QC inspector. The next level of review did not pick up the error. The Staff was advised innediately.

(Tr. 17179-17184, 17,356). The QC inspectors involved were suspended and retrained. (Tr. 17,181, 18,646-47) .

54. Another quality assurance problem involved the bypassing of hold tags. Dr. Landsman explained that preserving the integrity of hold tags is of particular importance with respect to the underpinning -

process. Certain operations in the underpinning are so crucial that if they are not done correctly and the next step of the work begins, the building may drop. (Tr. 16,696).

55. In early llay,1983, MPQAD placed hcid tags on drifts used for access and excavation on tunnels under the turbine building. Due to extensive gaps between the drifts and the plate attachment, the hold tags were placed. By walking through the drifts, workers violated the hold

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tags. When this violation was discovered, soils work was stopped. The next day, work was able to resume. (Tr.17,402-04, Stamiris Exhibit 85).

56. Also in the spring of 1983, CPC encountered further difficul-ties in drilling. (See i to , supra.)

56a. We find that in the first half of 1983, CPC has run into some difficulties in implementing remeidal soils work. They do notr rise to a level requiring stricter controls that are already in place, but do

? rsh aN reinforce the need to retain these controls.

k'I%.b Technical matters which appear unrelated to quality assurance implementation

57. We also heard testimony about a number of other occurrences as CPC impl.emented the remedial soils fixes. However, there was no evidence presented that these instances reflect poor quality assurance implementa-tien. To the extent they are concerns at all, they are technical matters, which we believe can be worked out between CPC and the Staff.

These instances are (1) anomalous readings of settlement data for the electrical penetration area at the auxiliary building (Tr. 14,671-74,

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17,169, Sinclair Exhibit 4), (2) the appearance of Service Water Pump Structure cracks that reached the alert level Tr. 14,370,14,659-14,66k2, 17,154-17,156) (3) the appearance of cracks in the containment building (Stamiris Exhibit 50, Tr.14,594-14,600)E/, (4) cracking of the FIVP during jacking (Tr. 14,641-42, A

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-9/ In fact, Ms. Stamiris moved to reopen the on record on the grounds that the cracks in the containment and the anomalous EPA riadings called into question the technical adequacy at the remedial fixes.

The parties were, of course, permitted to offer evidence in support or in opposition to the motion. We denied Ms. Stamiris' motion, indicating that there was nb evidence that either of those occur-rences gave rise to a significant concern about the remedial fixes.

Consumers Power Company (Midland Plant, Units 1 and 2), LBP-83-50, 18 NRC 242 (1983).

14,647-14,662, 17,018-17,121, 17,145-17,149IS/(5)inabilityduringthe pier load to transfer the load down to the bottom of the pier.

(Tr. 14,370-71, 14,663-14,671, 17,162-63, 17,170.31/ and (6) encountering of concrete backfill during excavation beneath the turbine building.

(Tr. 14,628, 16,197-16,199, 17,137-17,138).

1. Stone & Webster

58. A significant step towards improving implementation of soils work is the retaining of Stone and Webster assisted by Parsons, Brinkerhoff, Quade and Douglas, Inc. to assess CPC's performance of the underpinningwork.]2/

10/ But see 5 to , infra, where we discuss the Staff being critical of the time span for which data was being taken dgring the jacking of the FIVP. ,

11/ We differentiate between this technical concern and the aspects of

~~~

the load test which call into question quality assurance implementa-tion. See 1 to . Also, after the load test did not work the way it should have, CPC and the Staff met. In doing so, the Staff raised some technical questions about the underpinning process.

.They are documented in Board Notification 83-174. We will be kept apprised of the resolution of these concerns. If appropriate, the record may be reopened.

12/ This third party team will be referred to as the " Stone and Webster" team.

59. The selection of the Stone & Webster team is described in de-tail at t to ,su6Fa.andneednotberepeatedhere. Rather, at this point, we will describe what the Stone & Webster overview entails.

60. The overview consists of assessing the adequacy of construction and quality assurance procedures themselves and evaluating the ,

implementation of those procedures. Stone and Webster also reviews design work packages for adequacy and accuracy, evaluates the QC inspector requalification and recertification program, and assesses the training of remedial soils workers. (Mooney, prep test.10-11, -.

Appendix 4).

61. Stone and Webster holds daily meetings with CPC and Bechtel personnel. The Staff is invited to attend. Weekly, Stone and Webster submits reports summarizing the activities observed, meetings attended, quality' documents and records reviewed and observations made. When the team observes an action that displeases it, a "Nonconformance Identifica-tion Report (NIR) is written. NIRs remain open until CPC provides an

7-._.-.

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adequate resolution. Every three months e detailed report is submitted to the Staff. (Mooney, pp. 13-14).  ;

62. The team will remain on site until it is satisfied thht (1) the design intent of the remedial construction is being fully implemented and (2) the remedial soils work meets industry standards. (flooney, prep.

test. 11-12).

63. In April 1983, Stone and Webster submitted its first Ninety Day Report (CPC Exhibit 33). With a few exceptions, the team found that the work was being perfomed in accordance with good industry practices. The

. team was also satisfied with the ability of MPQAD soils parsonnel. (Id.

5-1 to S-2). Stone and_ Webster however acknowledged that the work that is observed had not been enough to pemit a complete assessment of under-pinning activities (Id. at S-3).

64. Intervenors att=-ted te ;h:4&-t4 Tat (ertain members of the Stone

& Webster team did work at nuclear power plants heavily cited for quality assurance violations. (Tr. 17,529'-17,273). However, there was no evidence that any of the individuals were directly responsible for poor quality assurance implementation. The mere fact that a team member happened to be on site at a time when a plant was heavily cited for -

noncompliances is insufficient. In fact, with respect to key supervisory personnel the evidence is to the contrary. fir. Shafer checked with utilities where those few members had been employed to determine if they had done acceptable work. (Tr.16,110-16,111,16,10.1,16,127-28). This was in addition to assessing that the individuals met the criteria for independence. (Tr. 16,110).

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65. Intervenors ateo attempted to cast doubt on the competency of the Stone & Webster team by showing that Staff inspectors made _ findings which Stone and Webster did not make. (Tr. 16,132, 16,159, '

l 17,240-17,249). However, Stone and Webster, like the Staff, cannot look at every area of soils work. (Tr.16,144). Accordingly, the mere fact that the Staff found a violation not found by Stone and Webster does not cast aspersions on the competence of Stone and Webster. Furthermore, the examples given do not support the claim that Stone and Webster is not I competent.1 I l

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-13/ Example given include use of IPINs in soils work. Tr. 16.132-16,136. IPINs however, were not abused in the soils area.' (1 to , infra.) Other instances offered were the dispute over Ee need to vibrate the concrete. (Tr. 16,137, 17,240-41) and the need to increase the jacking of the FIVP. (Tr.17,248). We find these instances to be more reflective of technical differences of opinion rather than poor implementation of quality assurance (5 to ,

supra). Another instance noted was the problems with the recertification of soils personnel. (Tr.17,247). However, the problem was discovered only four days after Stone and Webster arrived on site. (Mooney, prep. test. p. 12, Midland Section, October 1982 testimony, Attachment la). Furthermore, review of the recertification process was not placed within the scope of Stone and Webster's contract until February 1983. (Mooney, prep. test.,

p. II, Appendix 4). Another example was the Staff's concern that training should extend to craft personnel. (Tr. 17,246-47 ) .

However, the concern was discovered prior to Stone and Webster's arrival on site (Midland Section March 1983 testimony, Attachment la, Details Section, p. 2) and with one exception, resolved prior to the Stone and Webster assuming responsibility for observing the training program. (Attachment Ic, Details Section,

p. 32, Mooney, prep. test., p. 11), Appendix 4). Finally, a comparison was attempted between Stone and Webster's finding that MPQAD inspection plan were adequate (CPC Exhibit 33, p. 6-1) and the noncompliance cited in Inspection Report 83-03 that CPC's soils section was using an out of date drawing to review work at Pier 11.

(Staff Exhibit 18, Notice of Violation, p. 1) The violation however, had nothing to do with quality plans. (Tr. 16141).

66. We have heard no evidence that leads us to conclude that the l Stone and Webster team is not fit to overview remedial soils work.

,.j Quality Imornvamant Prooram

67. We also heard testimony about the Quality Improvement Program (QlP). The QIP is a program whereby management attempts to instill in the employees the philosophy that work must be done right. (Tr. 17,078)

The QIP encourages everyone to participate in attaining quality and to offer feedback. (Tr. 17,079-80). Individuals or groups who make a

s significant contribution to quality are rewarded with a picture in a brochure and a button. (Tr. 17,079). TheQIPinvolvesbothsofisand balance of plant work. (Tr. 18,113). It began as a Bechtel prkgram in the fall of 1981. In September 1982, the QIP was expanded to include all personnel involved in soils work. (Tr. 17,082). Mr. Rutgers and Mr. Mooney both testified that they believed that the program led to improvements in quality. (Tr. 17,084-85, 18,113). Mr. Shafer had doubts about the effectiveness of the program. (Tr. 16,830) . -

68. It is difficult to assess the extent to which the QIP contri-buted to better quality. Such an assessment is, however, not necessary.

We encourage CPC to adopt programs such as QIP. However, rather than attempt to calculate the input that the QIP has on quality, w.e will focus on the work itself and determine the extent to which CPC's performance of that work requires escalated regulatory action.

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k. Greater Management Involvement

69. CPC also committed to ha'ving greater management involvement in remedial soils work.. (Keppler October 1982 testimony, Attachment F, pp.2,5). In particular, reporting chains to senior project personnel have been shortened. Mr. Mooney briefs Mr. J. Cook at least once a week. -

(Mooney, prep. test. , p. 20) . Twice a month, Chief Executive Officer John Selby visits the site for about four hours and receives briefings on remedial soils work. (Tr. 17,313-14).

1. Conclusions

70. We have considered carefully CPC's performance of remedial soils work since the hearings that were held in July and August 1981. We are mindful that it is inevitable that the worke'sr will make mistakes, l

- s - - - ,- -- , . - - - - .. - . - , ,, - - - .,--

~~

which should be picked up by quality control. We also recognize that quality control will miss deficiencies that a quality assurance [ audit should then pick up. ' Finally, it is inevitable that the Staff huring its inspections will find regulatory, non-compliance not found by quality control and quality assurance. ( T r. 15 ,561 -15 ,564 , 16 ,223-16 ,228 ) . Even so, it is clear that before the work authorization procedure was instituted, CPC was having significant difficulty with implementing quality assurance for remedial soils work. The difficulties further manifested themselves in CPC's inability to carry out the retraining and recertification process.

71. Those difficulties justify the measures taken to assure that CPC will be able to properly carry out its remedial soils work; in particular the April 1982 Order and Stone and Webster assessment. We find the Stone and Webster program to be an acceptable overview of remedial soils work. We are also satisfied with the manner in which the Staff has implemented the requirem'ents of our April 30,1982 Order. We find that they have successfully kept the amount of soils work done to a level that CPC can manage. We also trust the Staff's judgment in both assessing if and when work can be approved in larger segments and for ~

withholding approval should that be necessary.

72. We have examined the work done since the Staff in December 1982 gave CPC approval to begin excavation. Certainly, there have been some difficulties. CPC should take care that these difficulties not continue.

However, they do not rise to a level mandating us, at this time; to impose stricter requirements than are already in place.

's l

73. We have also examined the steps CPC has taken to improve its performance of remedial soils work. We are pleased that CPC has done so.

We find to be a positive step, CPC's commitment to apply the excavation permit system to all anticipated excavations. However, what is ultimately inportant is whether the remedial soils work is done properly.

74. It is the Staff's position that remedial soils work may proceed subject to the third party overview and the requirements of our April 30, 1982 Order. (Keppler October 1982 testimony, p. 6, March 1983 testimony, pp. 3-6, Tr. 14,685). We a, gree. However, should CPC prove itself unable to properly implement the remedial soils work, we expect Staff) to take appropriate action. __ ils M

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February 15, 1984 V@A M M NA u , case us/

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[File N6 L JANUARY 20, 1984 MEETING WITH BILLIE GARDE (AlTEtlDEES. vu uuNG:, TAYLOR, AXELRAD, BURNS)

The meeting was held in Mr. DeYoung's office at noon on January 20th.

Msl. Garde had been invited to discuss concerns that she had expressed to Jane Axelrad concerning the staff's recent enforcement action against Midland for the violation of the Board-ordered construction permit condi-tions. Ms. Garde opened the meeting by saying that she appreciated the opportunity to meet with Mr. DeYoung. She wanted to say that she had some very strong feelings about the action that the staff had taken. She said that, the more she thought about it, the " madder she got" and she was very distressed. She thought that Mr. DeYoung had made the wron' g judgment in taking enforcement action for violation of the Board order. Mr. DeYoung asked her what she thought he. should have done. Ms. Garde believed he should have imposed a civil penalty in addition to the management audit.

~

She emphasized that the management audit was something that she had been seeking "for a long time".. It had appeared since October that the staff was going to require such.an audit and, thus, the order requiring the audit really was nothing new.

She viewed the history of NRC dealings with Consumers over the past couple of years as a series of "line drawings." After the $120,000 civil penalty for deficiencies in the diesel generator building was issued, Jim Keppler at a meeting on the CCP said he was "on the fence" about Midland. He had said that he was not wholly prepared to conclude that there was adequate assurance of quality necessary for licensing of the plant. In Ms. Garde's view, Mr. Keppler gave Consumers Power Company one last chance after the results of the Boos investigation on possible false statements made by Consumers during a meeting with NRC. Mr. Keppler had said he was on fence with that case and, in effect, gave Consumers one last chance. By not taking, in her view, any " strong action" with respect to the " Board-order violation," Ms. Garde believes that Mr. DeYoung undercut Mr. Keppler. She said that Consumers always plays NRC against itself and played that game $

here and won again this time. Mr. DeYoung emphasized that he did take action against Consumers by issuing the order to compel the management audit.

Billie Garde said again that she would have issued a civil penalty and the order.

Ms. Garde believed that the meeting with Consumers Power and Mr. Miller, its counsel near O' Hare airport " looked bad" because the same basic questions concerning violation of the Board order were under adjudication before the Licensing Board. Ms. Axelrad and Mr. Burns pointed out that nothing was improper about holding such meetings with a licensee on enforcement matters even though there might be a related adjudication pending. Again, Ms. Garde emphasized how she believed that the failure to take stronger ac' tion undermined -

the credibility of Mr. Keppler and the NRC and that the appearance caused by the meeting. enhanced that " credibility gap." She noted that, on the Midland Plant, Region III .is the only place in the. country where she will turn a

, whistleblower over to someone from the NRC without an a'ffidavit.'

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Mr. DeYoung emphasized that a civil penalty merely avoid's the problem  !

at Midland. Consumers could pay the civil penalty and walk away from what he believes is the underlying problem, thatsis, the adequacy of the management of the Midland project. By issuing the order, NRC requires the audit, makes Consumers do it, and makes them put recommended changes into effect. He noted that, in an earlier circumstance involving the Cooper plant, the audit was very successful in turning around and improving t!ie operation and management of the plant. He pointed out that, while Cooper received a $112,000 fine, the audit itself cost some one $120,000 and has a 3 to 4 million dollar recurring cost annually. Mr. DeYoung said that he didn't believe his action undermined the Region and that Mr. Keppler fully supported the action that he took. He noted that the staff had discussed among themselves the possibility of issuing a civil penalty, but, having considered these views, he determined on balance

", that a fine was not going to correct the problems at Midland. Mr. DeYoung said that he pushed for the audit from the beginning and, when Consumers Power had indicated that it would do it, he enphasized to Consumers that it had better come in with a very good proposal.

Mr. DeYoung indicated that we had held the meeting near O' Hare airport in late November because, after the initial enforcement conference, Consumers Power indicated ~ that NRC had not heard all sides to its story.

He said that he is always willing to meet people to hear their views.

Billie Garde noted that, since the opportunity had been given ,

to Mr. Miller and Consumers, the same chance to present her views should have been given to her. Mr. DeYoung said that that may have been appropriate and that we may have missed the chance by oversight here to provide that opportunity. He said that he would try to remember that in the future and asked Jane Axelrad to be sure that he does not forget to consider meeting with other interested persons when similar enforcement situations arise which are related to some ongoing licensing oroceeding.

Billie Garde said that she believed that she got "90 percent" of what she wanted in her 2.206 petition and was fairly happy with many of the actions NRC took. She again emphasized that, when the order came out, it was overshadowed by the fact that most people understood that Consumers ~

was going to do an audit and by the fact that, on the same day the order was issued, new developments arose out of a meeting at Midland regarding cracking in the diesel generator building. With respect to the cracking issue, she said Consumers Power admitted essentially at the meeting that it did not have sufficient crack maps refl~ecting cracking identified in the buildings. Mr. Mooney of Consumers Power said that his understanding was that Consumers only had to map cracks in buildings which were identified in 1979 and beyond. She said that the NRC staff from Region III was " ready to explode" when they heard this explanation. As a result, she said, the crack maps are not accurate, and we do not know where all the cra~cks are.

In her view, this latest episode was symptomatic of Consumers Power's attitude of looking at things as narrowly as possible.

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A She said that she disagreed with her colleague Tom Devine over the results of the Torrey Pines Technology review of Zimer because she thought that Torrey Pines pointed the finger at Messrs. Dickhoner and Borgman. She said that she hopes the audit here would be as comprehensive, and she believes that Mr.

DeYoung has to set the line by, in effect, saying " Consumers, you had your last chance on the Board order violation."

Mr. DeYoung changed the topic of the conversation and asked Ms. Garde for her thoughts about Catawba since she had filed a 2.206 petition regarding

' that plant. He asked her for her views about Duke Power Company. She said that she viewed them as " arrogant and not as good as they think." She believes that the combination of Duke Power Company management and Region II has left Catawba "in a mess". She stated that, if any utility cculd build a

! plant "by the seat of its pants," Duke was probably the one, but her primary

concern is the as-built condition of the plant. Because of the indeterminate 3 nature of the plant, the adequacy cannot be assessed in the absence of a look at.the as-built condition plant.

i She said Duke's response to h'er petition does not hold water. Quite simply, in her view, procedures were not followed at Catawba. In her view, the evidence at Catawba is better of quality assurance breakdown than any other

! plant because there werer ducated people who had built nuclear power. plants at two other Duke sites, and they had covered themselves by writing down j what they thought were improper handling of nonconformances and improper .

! construction practices. She noted that there were some 40 diaries kept by l welding inspectors'when they were-told .not to document their quality concerns.

}

, In her view, Duke is hoping th'at the NRC will trust them because Duke has

done well in the past. She says that she has called approximately 100 quality 1 assurance inspectors at Catawba and some 70 percent agreed that j procedures were not followed and that the electrical and civil people are not willing to say that electrical and concrete construction is satisfactory. She believes that Duke is not willing to do any ba

kward

look at the adequacy of Catawba. She believes that, if the plant l was in Region III, it would be shut down given the actions at Zimmer i and Midland, but she does not believe that Region II has been aggressive i enough with its oversight of Catawba. l i Mr. DeYoung asked her, with regard to the 2.206 petition, whether he should j really be the decisionmaker or whether the regional administrator who is closer to the situation should decide the petition. Billie Garde said that Mr. DeYoung should decide because in this instance it would not be satis-factory to have Region II make the decision since Region II is "part of the

problem" at Catawba. She said that she does not file 2.206 petitions lightly

! and she views the portions requesting further OIA and OI review to have been granted, but she believes that Mr. DeYoung should not defer to Region II since it has an inherent " conflict-of-interest" in determining the petition. -

(

Mr. Taylor asked her whether she believed that there was a substantive

hardware issue'at.' Catawba. She said she believed that there were hardware >

l- deficiencies and that a po'od source was the MAC Report which has details of

, hardware problems. Although the MAC Report has other failings, she believes a

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, .. .,o that Vol. 2 of that report did identify actual hardware problems in the plant.

She said however, that though MAC concluded that Duke had fixed soae 130 hard-ware items identified in its report, the hearing yecord contradicts that conclusion.

Mr. DeYoung closed the meeting by committing to meet with Billie Garde in th,e future, when appropriate.

Steve Burns cc: R. DeYoung J. Taylor J. Axelrad -

Distribution ROED rdg

• ROED sub

. Burns chron Lieberman info KC/LC/RH info ELD rdg J. O'Reilly, Reg. II J. Keppler, Reg. III E. Christenbury, OELD I

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7. Follow-up of allegations should be professions 1 in scope anddepth. If it is appropriate that an inspection be made, it should be made.

8. Without exception, the individual making the allegation should be promptly advised of the results of inspection follow-up action so that they are aware that their problems Were addressed. If for some reason there is unusual delay in providing the results, the person should be advised so that he does not feel his allegations are being ignored.

9. An " audit trail" - to include personal interview records - should be established so that NRC actions can be properly justified if necessary.

All allegations should be entered in the allegation tracking system..

10. The final report should set forth the, facts clearly, dispositively, and in a style that does not belittle or disparage the person who brought a safety matter to our attention.

Licensee Actions

1. Licensees should be encouraged to take allegations seriously. Programs such as interviews of all employee's who terminate should be encouraged.  ;

i i Such programs should be monitored by NRC . Licensee actions do not l

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relieve us of our responsibilities, but effective licensee sciions may l l

reduce somewhat the n, umber of allegations we receive.

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. 2. It should be advantageous under some circumstances to have the licensee address the validity of allegations to the NRC. If so, confidentiality E must not be breached. Licensees can be asked to address the validity'of allegations only if in so doing the person making the allegation is not exposed. One vehicle for accomplishing this is a 50.54(f) letter.

The person making the ellegation must be informed that this is not handing the issue over to the licensee, but that NRC will review the licensee's report. Such a review should, of course, not be peremptory.

! Confidentiality

1. Staff should recognize that in many cases individuals making allegations feel that they lay their jobs on the line when they approach the NRC.

All our activities must be sensitive to this, even when no explicit confidentiality agreement has been executed. Identities of sources will

not be voluntarily exposed by the NRC unless it is clear that the individual concerned has no objection. As a general rule, the 'need to know' approach should be used when dealing with the protection of an person's identity.

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2. Staff should assure that it is clear to all concerned if and on what

- tenns anonymity of a. person making' an allegation is to be protected. In

.$ every case the individual shall be asked if anonymity 1s desired. A ,

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clear record should be maintained for the files to preclud$1ater mis-understandings. A Co,nfidentiality Agreement (see attachment) should be executed with the individual, if necessary and possible.

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3. If at any time for any reason confidentiality is breached or jeopardized, the person should be so advised, the reason explained and remedial measures j

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Miland Concerns Raised bt I&E Ron Cook  :

i

1. The periodic personnel appraisals of the Bechtel onsite QC staff is influenced by the Flant Superintendent (Leo Davis). It is alleged that L. Davis documents derogatory comments on those who have identified frequent inspection findings (i.e. , extent of adverse coments are proportionate to the number of inspection findings) .

Gilray's Coment:

(a) QC staff should be independent of plant superintendent and report to the offsite Bechtel Construction QC organization. Accordingly, the appraisals should not be influenced by the onsite plant superintendent.

This can lead to intimidation of the QC staff whereby their interest

~

could be aligned more to cos t, production, and schedule rather than to QA/0C concepts.

(b) In the management audit, inquire (1); how appraisals of QC staff are conducted and by who; (2) to what extent.are. appraisals comented on by the plant superintendent; (3) spot check at random three QC appraisals; and (4) are procedures in effect describing the apprai-I sal system and are they consis tent with mana5ement's views?

Appendix.4 ', I (Refer to Sec. 2.3 of TI 2512/07^for additional quidance.)

2. The Plant Superintendent (Leo Davis) determines the required onsite QC staff size and qualifications. It appears L. Davis.has shown a tendency to want QC types who are not dedicated, aggressive QC inspectors. He is more interested in acquiring QC inspectors who can be easily swayed by construction management.

Gil ray's Comment:

a) The selection, size, and qualification of onsite QC staff should not e the responsibility nor be influenced by cons truction management.

' bS

( .

o

-2 The QC management should have these responsibilities (note la:connents for rationale).  ;

(b)' In the management audit inquire: (1) who is responsible for the selet-tion, size and qualifications of the onsite QC staff and what guide-lines are available for making this selection?;*(2) are procedures in effect describing the selection of QC staff and are they consistent with management's views?; and (3) interview the onsite QC Manager (Gene Smith) and detemine his involvement in the selection, size, and quali-fications of the QC staff. Also check on his involvement in the apprai-sals of the QC staff. Try te detemine his strengths and weaknesses.

(Can he be easily intimidated by L. Davis?) ' (Refer to Sec. 2.2.2 of Appendix 4 \

TI 2512/07^for additional guidance.)

3. There appears to be a high attrition rate of QC personnel because of intimidations by construction and the lack of strong backing of the QC organization and top management.

Gilray's Comnent:

(a) In the management audit (1) ask for the turnover rate of QC employees and inquire as to the reason for this turnover if high percentage (2) spot check on a random basis three personnel files of employ'ees who have lef t to try and detemine their reasons for leaving; and (3) if time pennits, interview Howard Smith and Gene Smith on this subject.

4. The backlog of Deviation Reports (NRCs) appears to be aggressively being cleared-out by a pencil exercise rather than by a thorough investigation an'd esalvation of each report and assessment of adequate disposition, cause, and need for cor-rective action.

O What are the criteria for detennining QC 8 QA staff size? , g,d-b g-(.S

. o ..

1 1

i Gileay's Coment:

(a) This should be looked at by Ron Cook and C. Jones. I

5. There appears to be demonstrated lack:of strong QA/QC support in the following two areas: placement of core barrel in the. vessel. QA ( A11en) identified open items but were essentially ignored by QC super. visor (Turnbu11) until he realized that the resident NRC insnector (R. Cook) had similar concerns; and drilling operutions to be conducted sometime in March did not have proper QA/QC controls in place prior to start of activity. CPCo did not start work at the advice of I &E.

Gilray's Comment:

(a) Try and get more factual history on the above two cases and pursue these cases with L. Davis and Gene Smith as to their side of the story.

(b) Then pursue with Cook and Rutgers as to their knowledge involvement, and actions to resolve the problems. Draw . conclusions on management dedication to QA/QC and involvement to assuring timely resolution of problems .

I e

6 O

Proposed Inspection Plan of'CPCo an_d Bechtel Management Involvement

1. .-

Critical Elements and Objective '

Verify adequate and effective management involvement in the implementation of the site quality assurance program relative to its s tatus . problem solving, .and re-sources support.

2. Gilray's observations _ and proposed soggestions:

a. CPCo has described their corrWctive. action. program relative to the soil settlement problem in a memo frofo J. Cook to J. Keppler dated April 30, 1981.

On paper, this program looks good recognizing referenced appendices are yet to be transmitted. I would suggest that these corrective action items be substantiated at CPOo and that indeed they are being implemented effectively. Of particular concern .ere the improvements described in Sections 3.1, 3.2, 3. 3, & 3.4. I would use TI 2512/07 Appendix 4 to in-vestigate these areas.

The most important elements of the interviews is to get a clear under-standing of:

(1) Prompt identification of problems to technical and 'QA/QC managefrent levels both onsite and offsite and their involvement in assuring adequate investigation as to the cause of the probleins and the'ir timely resolution.

(2) Management's understanding of the importance of QA/QC as a fundamental corner stone to doing:the. job iright and management's dedication and involvement in emphasizing QA/QC to managers, technicians, 'and craf t worke rs .

b.

Because of time limitations I:would concentrate extensive oiscussions with

I r Onsite Bechtel Plant Superintendent (L. Davis), Onsite Bechtb1 QC Super-i

. visor (Gene Smith), CPCo Onsite QA Supervisor, Offsite CPCo Midland Project

{

1 Office V.P. (J. Cook). Offsite Bechtel Project Manager (Rutgers), Offsite CPCo QA Manager (B. Marguglio, W. Syrd), and Office Bechtel QA Manager

)

(J. Millandin).

c.

Fold into the discussions the'following generic questions to gain an appre-ciation of the consistency or lack thereof to recognition of current Midland problems :

(1)

What are the five most significant problems at the Midland project i as of today?

(2)

What are the five most significant QA/QC problems at the Midland pro-I ject today? )

(3) What is being done to resolve these problems and what is your specific involvement?

(4) What are your personal views and thoughts in the resolution of these problems ?

d.

Prior to above discussion, identify the most substantive I&E findings in the las t three IE inspections tabt can be categorized as major problems (defi-ciencies) and ask each interviewae their management involvement, i.e.:

(1) Are they aware of the findtngs?

(2) Do they consider them varlid?

(3) What do they perceive to be the causes that contributed to each problem?

(4) i How were they informed of each. problem and what was (1s)}their involvement in resolving the problem?

(5)

What is their awareness of upper management's involvement in resolv-ing each problem?

(6)

What do they perceive to be rQA/QC roles in resolving each problem?

e.

In the above discussion. I would.suggest factoring the following elements of the inspection checklist TI 2512-07 Appendix 4, " Project Management - Site."

2.3.7 Value of Staff Site Appraisals

3. Management Involvement with strong emphasis given to:

3.4.1 Employee Interfacing 3.4.2 Management Interms t 3.4.3 Management Availability 3.4.4 Management Support 3.4.5 Dedication to Quality i

f.

In CPCo's presentation to Region III., Glen Ellyn, March 13, 1981, they s tated:

(1) The Management Analyses Co. , an independent consultant, has been en-geged to assess the adequacy of the corrective actions taken for items previously covered in TO CFR 550.55(e) Reports, the quality of supplied hardware currently onsite and the overall effectiveness of the quality assurance program; (2) Philip Crosby Associates. Inc., an independent consultant, has been engaged to provide quality assurance censultation and conduct seminars for CPCo and Bechtel personnel to improve quality assurance program implemen ta tion.

__m.. - - _ . , , . . _ _ _ , - - . _ _ _ . _ 4 _. . _ . , y _- -._ m._. .- - , _ ._ - ._. --. ._ _ . - - _ _ _ - - _ . - -

I suggest discussions an these two items be held with J. Cook',, autgers,

' B. Marguglio, W. Byrd, and J. 'Millendin as to their knowledge as to what has been accomplished in these ,two arreas and their thoughts as to what these two independent efforts will have on enhancing managerment's role in 'QA/0C.

Also, I would obtain and nead >any reports (confidential or otherwise) that have been generated by MAC and Cnosby as a result of their work at OPCo.

g. Per C. Williams I have sumarized sqy discussion with R. Cook regarding his particular concerns and also provided coments which ought to be factored in the inspection.

iJohn W. Gil ray i

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[p2 aarf'g'o UNITED STATES 3 , r. NUCLEAR REGULATORY COMMISSION g WASHINGTON, D. C. 20555 pg1 MEMORANDUM FOR: Robert F. Warnick, Director Enforcement and Investigation Staff Region III James P. Knight, Assistant Director for Components & Structures Engineering Division of Engineering ,

FROM: Thomas.M. Novak, Assistant'Direclor for Licensing .

Division of Licensing

SUBJECT:

DRAFT PROCEDURE FOR NRR SUPPORT TO REGIONS Enclosed for your comment is a draft procedure which would provide guidance to NRR members performing support to the Regions. This draft represents our initial step in establishing such guidance and has b'een prepared with the Midland remedial soils support effort in inin'd. However, I would also be interested in your views as to broader application of such a procedure.

Thomas M. Novak, Assistant Director for Licensing Division of Licensing

Enclosure:

Draft Procedure cc: See next page A

89 Robert F. Warnick James P. Knight -

- l cc: D. Eisenhut  :

l R. Vollmer -

t

]

. R. Mattson i H. Thompson T. Speis J. Keppler, R-III C. Harwood, PPAS

~.~..

l l

6

- - _ - _ _ _ _ - . _ _ _ . - - _ - _ _ m

PROCEDURE FOR NRR SUPPORT TO THE REGIONS i

I. Objective

{

The objective of this procedure is to identify proper handling of work perfomance by NRR for the Regions for both NRR and Region personnel.

As procedures for requesting such work are already in place this is ,

not addressed here. The tem "kicensee" as used in this procedure means the licensee or applicant and all its contractors. )

i II. Reporting .

Any NRR reviewer assigned to work for the Regions under the proper

_r.-.._

' planned accomplishment number shall look to the Region management for technical and policy guidance and review related to that assignment.

The Region will participate in all verbal comunications ~with the licensee, whether or not initiated by NRR or the licensee. Unless requested by the Region, in advance, documentation of significant verbal communications with the licensee is the responsibility of the Region.

The work products (memos, reports,etc.) produced by NRR reviewers shall be provided directly to the Region. Review and approval by NRR management is not required. Review and approval of work products

. . . . shall be perfomed by the. user organization (i.e., the Region).

However, copies will be provided to the individual's line hanagement for infomation. Changes to the NRR work product as necessary for

consistency, accuracy or clarity shall be made as deemed appropriate hy the Region.

When more than one member of NRR is involved with the same support task, coordination of information among the NRR reviewers during the task shall be achieved hy individual task members, or in ,

consultation with Region III as appropriate. Coordination of the work product shall be as directed by the Region. Any questions or difficulties associated with this process should be resolved by the Region. .

~

~ -

III.' Document Transmit'tal In the course of working for the Region an NRR reviewer may need access to material or documents which would not normally be submitted on the docket. To avoid any confusion, these documents shall be transmitted to the NRR reviewer from the Region. When review of these documents is completed they will be returned to the Region.

All review materials transmitted to NRR by the licensee shall be formally transmitted under oath and affirmation in accordance with HRR docketing requirements, and shall be made publically available except as provided hy 10 CFR 2.790.

As noted anden Section II above, the NRR reviewer shall provide all work products to the Region for management review and use. The Region shall consider these work products as it would'any input

3-from Regional staff, not as input from NRR. Copies of these work products will be provided to NRR management. -

. The NRR reviewer shall, however, notify both the Region and the appropriate NRR management of any information or changes encountered which are not consistent with the SER, hearing record, technical specifications or other licensing conditions, or which should be considered for licensing board notification.

, , g a WM e

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g 3A f f Cp g

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g UNITED sT ATEs NUCLEAR REGULATORY COMMISSION

$4 *.E WASWNGTON, D. C. 20555 s) J

....+

f Docket Nos: 50-329 OM, OL and 50-330 OM, OL APPLICANT: Consumers Power Company FACILITY: Midland Plant, Units 1 and 2

SUMMARY

OF MAY 11 & 12, 1983, SITE VISIT FOR UNDERPINNING PIER LOAD TEST On May 11 and 12, 1983, the NRC and its consultants visited the Midland site to view and discuss a load test installation for underpinning pier W11 located beneath the west side of the Turbine Building. Other topics were also discussed during the visit. The enclosed memorandum of May 27, 1983, and its two attachments surmiarize'tdis site visit.

nk Y Dar.1 S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing

Enclosure:

As stated cc: See next page

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• A r MIDLAND Hr. J. W. Cook ,

Vice President Consumers Power Company J945 West Parnall Road Jackson, Michigan 49201 cc: Michael I. Miller, Esq. Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq. Division of Radiological Health' Alan S. Farnell, Esq. Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza, Lansing, Michigan 48909 ,

51st floor Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq. St. Paul , Minnesota 55108 Consumers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive .

Midland, Michigan 48640 Ms. barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environ:tental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Company 720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)

Battelle Blvd.

Mr. R. B. Borsum SIGMA IV Building Nuclear Power Generation Division Richland, Washington 99352 Babcock & Wilcox 7910 Woodmont Avenue, Suite 220 Mr. I. Charak, Manager Bethesda, Maryland 20814 NRC Assistance Project Argonne National Laboratory Cherry & Flynn 9700 South Cass Avenue Suite 3700 Argonne, Illinois 60439 Three First National Plaza Chicago, Illinois 60602 James G. Keppler, Regional Adininistrator U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 1

M

J .

.L' Mr. J. W. Cook ,

2-cc: Mr. Ron Callen Michigan Public Service Commission 6545 Mercantile Way P.O. Box 30221 .

' Lansing, Michigan 48909 Mr. Paul Rau Midland Daily News 124 Mcdonald Street Midland, Michigan 48640 ,

Billie Pirner Garde Director, Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W. -

Washington, D. C. 20009 Mr.-Howard Levin, Project Manager TERA Corporation 7101 Wisconsin Avenue

• Bethesda, Maryland 20814 Ms. Lynne Bernabei Government Accountability Project 1901 Q Street, N.W.

Washington, D. C. 20009 f

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Supplemental page to the Midland OM, OL Service List Mr. J. W. Cook .

cc: Commander, Naval Surface Weapons Center *

. ATTN: P. C.-Huang White Oak Silver Spring, Maryland 20910 l

Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center .

P.O. Box 1449 Canoga Park, California 91304

, Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor '

477 Michigan Avenue l Detroit, Michigan 48226

~ '~'

Charles Bechhoefer, Esq.

l Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Geotechnical Engineers, Inc.

ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 9

,/ Ig UNITED STATES ,

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NUCLEAR REGULATORY COMMISSION y 4. ... 9ff,* j wasmNcioN. D. c. 20sss t .' L h /!

%, . .-~/f r MAY 2 71983 -

y MEMORANDUM FOR:

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George Lear, ChiefStructural and Geotechnical Engineering Division of Engineering THRU: Lyman Heller, Leader

/ Geotechnical Engineering Section

.f. Structural and Geotechnical Engineering Branch *

/[ .

Division of Engineering

-FROM: Joseph D. Kane, Geotechnical Engineering Section Structural and Geotechnical Engineering Branch Division of Engineering

SUBJECT:

SITE VISIT REPORT - TECHNICAL ASSISTANCE TO REGION III FOR MIDLAND PROJECT (TAC NO. 5134, PA 1163)

On April 25, 1983 loading of test pier Wll was initiated by Consumers Power Company to demonstrate the acceptability of the natural foundation soils for safely supporting the permanent underpinning wall beneath the Auxiliary Building. Geotechnical Engineering Section (L. Heller) was verbally notified of the start of the pier load testing on April 27, 1983 by Division of Licensing (E. Adensam). Conference calls between Region III, Consumers and GES on April 28 and 29,1983 and the Applicant's initial submittals of

• pier load test data (Federal Express on April 30, 1983 and Bechtel courier on May 1,1983) revealed that the anti-friction liner installed on the sides of Pier Wil shaft had not successfully eliminated side friction on the sides of the shaft. Because side friction will not be available to carry structural loads on the permanent underpinning wall, the applicability and acceptability of the pier load test results became questionable. Unless a final evaluation of the pier load test data eventually permitted a detennination of the portion of the applied jacking load carried in end bearing, the NRC staff had expressed the opinion that a second pier load test would be necessary.

A site visit to begin May 11, 1983 was arranged to' permit the staff to view the initial pier load test set-up at Wil which would include the installed instrumentation (Jacking pressure gages, telltale assemblies and movement dial gages). Representatives from Consumers and their consultants were to complete their final evaluation of the test loading of Pier Wil and then meet with the staff at the site to discuss their conclusions. .

The site visit to view the pier load test installation and to discuss the ,

results was held May 11 and 12, 1983. Representatives from Region III, GES, GEI, COE, Consumers, Bechtel, Stone and Webster, and Parsons-Brinkerhoff were __.

present on these two days.Ej nc4ehre 1 presents a report of the site visit

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Nhc 4,c , Q events pertaining to the/ pier load test written by GES consultant, Geotechnical Engineers Inc. Estesde 2 was prepared by Joseph Kane of GES to document discussions held with the Applicant on topics in addition to the pier load test and to provide the staff conclusions for the site visit. By copy of these enclosures, D. Hood, licensing project manager and R. Landsman, Region III inspector, are informed of the events and conclusions of our '

site visit.

.O J&

seph D. Kane Geotechnical Engineering Section Structural and Geotechnical Engineering Branch Division of Engineering

• Attachments: '

As stated . _ , , _

cc: w/ enclosure -

R. Vollmer D. Eisenhut J. Knight T. Novak G. Lear L. Heller D. Hood R. Landsman, Region III P. T. Kuo H. Singh, COE S. Poulos, GEI J. Kane wm i

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,, Attachment 1 l

/ GEOTECHNICAL ENGINEERS INC.

! JiL 1017 M AIN ST REET . WINCHESTER . M ASS ACHUSETT S Ot890 (617) 729 1625 *

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May 23, 1983

.J.'!O'. */#f/no Project 81907 "U'.II'duffT File 11.0 Ref: 81907-23 Mr. Joseph Kane

• NRR Project Officer U. S. Nuclear Regulatory Commission Division of Engineering, M/S P-214 Washington, D.C. 20555

Subject:

Site Visit of May 10-13, 1983 Midland Plant Underpinning Contract

Dear Mr. Kane:

Enclosed are four copies of our report on the subject site visit as it related to the pier load test.

Other topics were discussed at the meeting, such as:

Cracks in the Service Water Pump Structure, heave over the freeze wall, need to stop laying back the soil along the underpinning drifts, method of ringing the wedges to maintain load, and settlements due to underpinning to date.

These topics are not covered in this report as they will be coverd in the minutes of the meeting by the Applicant. ~

Sincerely yours,

. GEOTECHNICAL ENGINEERS INC.

C w Steve J. Poulos Principal SJP:ms Encl. _

cc: Mr. Hari Singh Mr. Reuben Samu els -'

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REPORT OF SITE VISIT May 10-13, 1983 -

MIDLAND PLANT UNDERPINNING Geotechnical Enaineers Inc. Ref: 81907-23 ~

May 20, 1983 Mr.

A site visit was made by Mr. Joseph Kane, Dr. Ross Landsman, Hari Singh, and Dr.

Steve Poulos to observe the bearing soil, the Wil. underpinning operations and the test pier set-up for Pier In addition, discussions were held about the Applicant's interpretation of the pier load test results.

The purpose of this report is to record our conclusions .

relative to the pier load test results and to report the results of static cone penetration tests made by the above party in Pier E8.

~

PIER LOAD TEST RESULTS The purpose of the pier load test was to determine the compressibility modulus, E of the bearing layer as' indicated by the soil s, and by the rate of secondary compression. During design it was assumed by the Applicant that Es = 3000 ksf and that the coefficient of secondary compression, C6 = 0.0005 to 0.001 (strain) per log cycle of time.

A concrete pier shown in Fig. I was tested to 600 kips. The sides of the pier were greased to reduce skin friction. However, the data indicated that substantial side friction developed.

Perhaps stratum. only two thirds of the 600-kip load reached the bearing As a result, considerable uncertainty remains about the ecuivalent modulus of elasticity of the soil, E s, based on the data.

The friction probably developed due to the shape of the sides of the pier shaft, which varied +0.5 in. over its height, as shown in Fig. 2.

Modulus of Hard Clay - The pier compression data and the Carlson stress meter data permit independent estimation of the __

side friction.

Figs. 3 and 4 show the load at the top vjt tip settlement, the estimated skin friction, and the estimated tip load vs tip site visit.

settlement based on the analyses provided during our From Figs. 3 and 4, the following modulus values are obtained at various stress levels:

Basis Bearing Equivalent Modulus, En, ksf Stress Surface At Depth Average .

ksf (Mindlin)

Carlson 8.8 2800 1540 2170 Meters 13.0 2680 1470 2080 (Fig. 3)

Pier 8.8 1620 890 1260 Compression 13.0 1600 880 1240 (Fig. 4)

AVG. VALUE AT 13 KSF = 1660 KSF The above values for the surface case are computed from the equation Es= 9 Eq. (1)

( 6/K B) .

where: q = stress at tip 6 = settlement at tip B = width of pier (2.8 ftt~

K = 0.75 = 1.0 x (1 u 2) u = 0.5 (undrained case)

The Mindlin solution for stresses within an elastic mass indicates that the above modulus should be multiplied by 0.55 to account for the depth effect. However, this solution over-corrects for real soils because it is based on the assumption that tensile stresses above the pier bottom restrain settle-ments. Real soils do not support tensile stresses. The average of the value of E s at the surface and at depth is used in the table above in the absence of (1) a more rigorous analysis, (2) knowledge of the distribution of skin friction on the pier, and (3) knowledge of the properties of the fill at this location.

Secondary Comoression of Hard Clay - Fig. 5, provided at the site visit, shows the apparent secondary compression in the test pier (Wll) for a top load of 600 kips. The rate of secondary compression is impeded by skin friction. It is not known what the value would be in the absence of skin friction. However, the bearing pressure at the tip is considerably larger than the design pressures. Therefore, the rate of se'condary settlement for the completed foundation can be expected to be smaller than shown for Pier Wil. __

The rate of secondary compression measured in all piers ranged over values that are greater than those anticipated ---

in design. The lower end of the measured range is at the f

upper end of the anticipated range at the design bearing .

pressures. For the completed foundation the group action of the piers will reduce the effect of skin friction on the rate of secondary compression. We would anticipate higher rates of secondary compression, perhaps by a factor of two, on average, '

than were used for design.

As was indicated by the Applicant during the site visit, it' is possible to maintain the jack pressure longer than antici-pated before transferring the load to the underpinning. In this way the long-term differential movements can be held to the ,

design values.

The important parameter with respect to design is the dif-ferential settlement between the underpinned foundation and the auxiliary building. Thus, the actual secondary settlement in inches / log cycle of time must be estimated before the loads are permanently transferred to the underpinning. Extrapolation of such data will provide the required estimate of differential settlement.

STATIC CONE PENETROMETER READINGS - During the site visit '

Messrs. Kane, Landsman, Singh, and Poulos took measurements of the static cone penetration resistance of the hard clay about 8 f t above the bearing elevation in Pier E8. The readings at various points on the bottom of the pit were taken af ter digging down 2 in. to 5 in, below the horizontal surface that was exposed. The measurements ranged as follows:

Penetration Depth Dial Reading on Estimated Undrained Proving Ring Shear Strength in. ksf 3/4 35-80 2.2 to 5.0 1-1/2 150 to 220 2.4 to 3.6 We found that the greenish gray clayef zones yielded the lower readings and the zones of tan-gray silt or silty clay yielded the higher readings. The silty zones fe]t harder to the touch. The plastic zones were at water contents a few percent above the plastic limit, which is consistent with previous data.

Although the silty zones give higher penetration resistance, it may be that undrained triaxial tests would show that silty samples have lower undrained strengths than clayey samples. ' ~

Disturbance during sampling could have a larger effect on the _.

silty layers than on the clay zones.

j

_4_

DISCUSSION - The undrained strength of the hard clay bearing stratum the increases slowly with depth according to data provided by Applicant. Therefore, the compressibility can be expected to decrease with depth.

For the above reason the modulus measured in the pier load test will be somewhat smaller than the modulus that would af-feet the settlement of a full size pier and the entire new foundation. Thus, the pier load test gives a low-side estimate of the actual modulus. .

The rate of secondary compression of the test pier is too low because of skin friction. The same applies for all other piers. Also, the rate of secondary compression (inches / log c.ycl e ) for the entire foundation will be larger than measured for individual piers, because a greater depth of soil will be affected by the loads causing secondary compression. However, the secondary compression will be lower for the deeper layers for the same reason that the modulus increases with depth. The result probably is a net increase in the rate of secondary compression. (inches / log cycle) with increasing size of bearing area.

The results of the static cone test results about 8 ft above the bearing elevation in Pier E8 indicate that the measured undrained shear strengths are about 3 to 3.5 ksf. Data pre-sented by Bechtel at the site meeting indicate an average undrained elevation.

shear strength of 6 to 6.5 ksf 8 ft above the bearing The reason for the difference is not known.

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Attachment 2 SITE VISIT REPORT MIDLAND' PLANT, UNITS 1 AND 2 (50-329/330)

DATE OF SITE VISIT: MAY 11 AND 12, 1983 -

REPORT PREPARED BY: Joseph D. Kane, GES, SGEB, DE, NRR General This memorandum has been prepared to document the discussions and actions that transpired at the May 11 and 12, 1983 visit with Consumers Power Co.

A list of attendees is attached and includes representatives from CPC, Bechtel, Stone and Webster, Parsons-Brinkerhoff, Meuser-Rutledge, Region III, GEI, COE and GES.

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The site visit was arranged to primarily view and discuss the pier loading at test Pier Wil. Other items viewed during this site visit included inspection of underpinning work beneath the FIVPs and EPAs, both east and west sides, movement instrumentation within the Turbine Building and the widened crack on the roof of the SWPS. Brief discussions were held towards the closing of the meeting on May 12, 1983 on lateral soil movement between Piers Wil and W10; the proposed backfill compaction specifications; lay back slopes of underpinning excavations; proposed pipe tunnel approach to control tower pier CT-1, (UAT approach); drilling holes in advance of installing temporary construction dewatering at SWPS; proposed modification of pier bracing; and presentation of monitoring data recorded during underpinning --

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The major portion pf the site visit on May 11, 1983 was spent in the field visually observing the underpinning construction. An approximate 2-1/2 ,

ho'ur presentation was made by CPC at the end of the first day which summarized the Applicant's evaluation and conclusions on test loading of Pier Wil. At the beginning of the second day the flP.C staff and its consultants met separately from the Applicant to review the information provided and to discuss their evaluation and findings. A joint meeting with the applicant was then held on the afternoon of May 12. The following

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paragraphs summarize the two day site visit discussions. -

Test Loading of Pier Wil. A brief discussion of the field and project soils organizations was presented by the Applicant followed by a summary of pier construction and load traitsferring operations which had been completed to date. Four representatives from the Applicant presented their evaluation of the pier loading test data. A slide presentation was shown of the foundation materials encountered in the pier excavations to provide the staff with a good understanding of the natural layering of the brown silt lenses in the gray stiff lacustrine clays. With respect to the best estimate of the soil modulus for the foundation soils, the Applicant concluded that values in the range of 2500 ksf to 3000 ksf were reasonable from their evaluation of Pier Wil test data and considerably higher values (in excess of 4000 ksf) were reasonable from loading of Piers W12, E12 and W9. The conclusions of the

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1. NRC staff and its consultants on the results of the pier load testing (soil modulus, Es, and the coefficient of secondary compression) are presented in Enclosure 1 (May 23, 1983 Report by Geotechnical Engineers, Inc.). The Staff position expressed at the May 12, 1983 meeting indicated that an equivalent soil modulus of elasticity equal to 1503 ksf was reasonable for adoption in design of the permanent underpinning wall and a differential settlement equal '

to 0.50 inch between the underpinned foundation and the auxiliary building was appropriate and reasonably conservative. The alternatives available to the Applicant resulting from the staff's position included the following:

a. Reexamine the des 4gn of the permanent underpinning wall for the impact of the lower design soil modulus and larger differential settlement.

The App'licant expressed a willingness to consider this alternative and get back to the Staff in approximately one week. Their decision would be provided in a telephone confere..ce to be coordinated with Region III.

The staff briefly discussed the extent of future documentation that would be required if this alternative were chosen (identification of soil modulus and differential. settlements addressed in structural reanlaysis, changes in soil spring stiffnesses and effects on structural design).

The effect on the margin of safety against bearing capacity type failure using cone penetrometer data and the results of shear testing on undisturbed samples was also to be addressed in the light of a potentially less stiff foundation material.

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b. Conduct a second-pier load test. This alternative would allow the

• Applicant to demonstrate that the soil modulus values are equal to or greater than the originally adopted soil modulus values by conducting a second load test where efforts to eliminate skin friction would be .

improved. In response to the Applicant's questions, the Staff and its consultants indicated that verification of lateral isolation along the -

sides of the pier shaft would be required, if this alternative were chosen, and an independent dual system for measuring pier tip settlement would be necessary. Installation of the Carlson concrete stress meters would not be necessary. Documentation similar to information 'provided for Pier Wil (max. test load, loading increments, etc.) woul_d..b,g_ required.

The Staff indicated a need to reconsider the time interval for maintaining incremental loads and resolve this concern.with the Applicant, if this alternative is eventually selected.

c. Conduct a plate load test. This alternative was proposed by the Applicant and was considered acceptable by the Staff and its consultants provided the applicable provisions of ASTM D-1194 were followed and a bearing plate with a minimum diameter of 18 inches were used. The Staff agreed that it would not~ be necessary to load the plate unto failure if the ultimate bearing capacity of 45 ksf were reached nor if the soil modulus exceeded 3000 ksf at the design bearing pressures. Authorization from Region III to proceed with the plate load test is necessary but NRR does ~~

not require further documentation prior to conducting the plate load test.

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o Crack Widening on Roof of SWPS. The site visit afforded the staff the opportunity to inspect a diagonal crack in the roof of the SWPS which had been reported to have recently widened in excess of 10 mils (max opening now at 3'5 mils). A report by the applicant that evaluates -

the crack widening had just recently been provided to Region III.

GEI again indicated its concern for the accuracy now being used in neasuring crack widths (calibrated microscope) and suggested a simple, more accurate and reliable measurement using a caliper and studs glued on either side of the cracks. Drilling of boreholes in preparation for the temporary dewatering at the SWPS were in progress on the day of the 4 -- site visit but neither dewatering nor underpinning has begun at the SWPS.

Reported Soil Movement. A lateral movement of soil between. Piers Wil (completed) and W10 (presently being excavated) was reported to have occurred the night of May 11, 1983. The approximately 2 to 3 foot deep zone was eventually filled with concrete before proceeding with excavation of Pier W10. A check on instrumentation in the immediate area of these piers did not indicate unusual movement.

Pipe Tunnel Approach to Pier CT-1. The Applicant questioned the Staff on its response to information previously furnished which covers the proposed modification for approaching Control Tower Pier CT-1 through the Pipe Tunnel (Drawings SK-C-856, SK-C-857 and SK-C-865). The Applicant stressed the importance of this work to its future construction schedule. The Staff agreed to respond with review comments within a week during the same conference call to be arranged which will provide the Applicant's decision on the alternatives to pier load testing.

Y Layback Slopes of Underpinning Excavations. Observations of construction operations during the site visit revealed an incorrect procedure being .

used by the underpinning contractor. Instead of bringing the lagging boards for drift excavations up to the bottom of the Turbine Building foundations, the upper boards were being omitted and the top of the excavations were being sloped inward. This procedure results in greater removal of foundation soil support than is necessary and creates the potential for larger structure movement. Following discussions with the Staff and its consultants, the Applicant agreed to avoid layin.g back any future excavation slopes and to provide bracing for the e'ntire depth.

Two short lengths of drift Bxcavations near the KC piers were to be corrected with the placement of upper lagging boards and backpacking.

Proposed Specification for Backfilling. A preliminary copy of " Technical Specification for Backfill and Compaction of Soil for Feedwater Isolation Valve Pits and Auxiliary Building Underpinning Construction'l was provided to the Staff.

The Staff agreed to review the specification for fulfillment of commitments made by the Applicant at previous audit reviews and to provide comments at a future date.

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Temporary Dewatering at SWPS. The Bechtel Resident Geotechnical Engineer briefly described the preliminary results of borings completed at the SWPS ,

that are in response to SSER No. 2 acceptance criteria requirements on i

groundwater control during underpinning. The NRC staff recommended that

! this information be provided to Region III with a brief engineering evaluation l

that includes an explanation for unusually low groundwater levels recorded in certain borings. Bechtel's RGE also covered the measures being taken to demonstrate the acceptability of probe jetting in the SWPS area. The staff agreed with Bechtel's procedures for checking the volume of soil material removed during jetting and recomnended this procedure continue. The Staff

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also recommended that 5 or 6 additional jet probings be performed in the fill

depth intervals where this material will be excavated and replaced and to I

monitor the time ~1nterval for advancing the holes for each 5 feet of penetration.

The staff expressed the opinion that proper utilization of both the measurements 1

of soil volume removed and the time for hole advancement should assure I

acceptable control to permit jet pcobing in areas where the plant fill soil will not be replaced. The final procedures to utilize jet probing in areas that will not have fill materials replaced require Region III approval.

Modification to Pier Bracino. In response to the Applicant's questioning on the acceptability of the proposed modification of pier bracing (Tie-Back System) the Staff indicated this was a matter to be discussed between the Applicant, Region III and Structural Engineering Section.

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Monitoring During Underpinning. During the site visit the Staff was able to view several monitoring installations in the Turbine Building and to observe ,

the control room for monitoring of Auxiliary Building movements.

Representatives from Weis,s, Jenny, Elstner and Associates, Inc. demonstrated their capability for calling for an immediate computer listing of temperature, ,

absolute and relative deflection, extensometer, Carlson stress meter and strain gage data. No presentation was made nor were discussions held on the monitoring data that has been recorded to date.

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NRC Meeting May 11, 1983 .

Name Company Dave Lavelle Bechtel - FSO Manager John Fisher B'echtel - FSO

. John Darby Bechtel - Resident Engineering Mike Lewis Bechtel - Res. Geo. Eng.

T. R. Thiruvengadam Consumers Power - Civil Eng. .

Steve J. Poulos NRR Consultant - Geotechnical Engineers, Inc.

Louis G. Silano Parsons Brinckerhoff Hari Narain Singh U.S. Army Corps of Engineers, Chicago Ross Landsman NRC, Region III Joseph Kane NRR, DE, SGEB b J. A. Mooney CPCo John Schaub CPCo R. Wheeler CPCo R. Wieland CPCo W. Kilker ,

Stone & Webster S. Loucks Stone & Webrter J. Gould Meuser, P ttle ge, Wentworth & Johnston K. Razdan CPCo .

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