ML20126L806
| ML20126L806 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/08/1981 |
| From: | Gallagher E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20126L803 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8106090627 | |
| Download: ML20126L806 (37) | |
Text
.,- ,-
(%
dj UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CONSUMERS POWER COMPANY ) Docket Nos. 50' 329
) 50-330 OM & OL (Midland Plant, Units 1 and 2) )
NRC STAFF TESTIMONY OF EUGENE J. GALLAGHER WITH RESPECT TO ,
QUALITY ASSURANCE PROGRAM IMPLEMENTATION PRIOR TO DECEMBER 6. 1979 Q. 1. Please'3 tate your name and position with the NRC.
A. My name is Eugene J. Gallagher. I am a civil engineer with C\/
ts the U.S. Nuclear Regulatory Commission. Since February,1981, I have been v . .
assigned to the Reactor-Engineering Branch, Division.of Resident and Regional Reactor Inspection, Office of Inspection and Enforcement. Prior to February,1981, I was a reactor inspector assigned to the Region I!!,
Reactor Construction and Engineering Support Branch, Office of Inspection and Enforcement. I was assigned to the Midland Plant (among others) from October,1978 until January,1981.
Since October of 1978, I have spent approximately one year of effort performing inspections, reviewing quality control records and procedures,
-observing work activities, reviewing Consumers Power Company (hereaf ter Consumers) responses to 50.54(f) questions 1 and 23, attending meetings and presentations by Consumers and Bechtel regarding the soil settlement
,. . natter at the Midland Plant.
, i
!8 3 0 6.0,90 (o ff
-2.
' N_.);'
Q. 2. Have you prepared-a statement of professional qualifications?
)
A. .Yes , a copy of this statement.is attachment No.17.
Q. 3.: Please' state' the nature of t responsibilities that you had with 'I respect-to the' Midland Plant, Units 1 & 2, from October, 1978 to December 6', - 1979.. ,
A. . As a civil-engineer inspector for the Region'III office of.
Inspection and Enforcement'I conducted five inspections prior to Decem-
'ber 6,1979 in order to (1) ascertain whether adequate quality assurance .
plans',' instructions and procedures ~had been established for the con-p -
struct, ion of the foundation of safety related structures, (2) provide an independent evaluation of the performance, work in progress and completed work' to ascertain whether activities relative to foundation construction were accomplished in accordance with NRC requirements, and (3) review the quality related records to ascertain whether these records reflected work accomplished consistent with flRC requirenents and license commitments.
The results.of these inspections prior to December 6,1979 are contained in the following NRC inspection reports:
50-329/78-12; 50-330/78-12, conducted October 24-27, 1978 (Attachment No. 2).
50-329/78-20; 50-330/78-20, conducted December 11,1978-January 25, 1979 (Attachment flo. 7).
50-329/79-06; 50-330/79-06, conducted March 28-29, 1979 (Attachment No. 8).
~
I L) ,
.l 1
1
., ,_ .- _, . . . _ . . . . . , - , - , _ . - . . . . - . _ , ,. _ . _ . . - - - . - . , - _ _ . . - .-..J
- 3-
'p 50-329/79-10; 50-330/79-10, conducted May '14-17,1979 (Attachment No. 10).
.50-329/79-19; 50-330/79-19, conducted September 11-14, 1979 (Attachment No. 12).
Q. 4. Please state the purpose of. this testimony.
A. The purpose of this testimony is to identify the quality assurance deficiencies which contributed to the soil settlement problem at the Midland Plant prior to the issuance of the December 6, 1979 Order.
t
- Q. 5. What ,is " quality assurance . comprised of ?
A. " Quality assurance"' comprises all those planned and systematic
( acti.ons necessary.to provide adequate confidence that a structure,
\ system,-or component will perfom satisfactori_ly in service. ' Quality :.
. assurance includes quality control. (10 CFR 50, Appendix B, Introduction).
Q. 6. What 'is " quality control" comprised of.
l A._ Quality control comprises those quality assurance actions related 'to the physical character'istics of a material, structure, component or system which provide a means to control the quality of the ,
e i material, structure, component or system to predetermined requirements. ,
(10CFR50,AppendixB, Introduction).
"' 7. Are soils work activities subject to 10 CFR 50, Appendix S?
Q.
~n,. -
, . , - , . , , . - , , , . , ,,,.,,,-, .. n,~, w-,..... ,,,a. . , , , . - , , - - - , , . . . . . ~ . , - - - . . . , , , - . . . ~ ,
l l
1 j
1
'[ T ' A '. General Design Criterion 1 of 10 CFR 50, Appendix A (Quality V Standards and Records) requires that " structures systems and components, important to safety be designed.Jfabricated, erected and tested to quality standards commensurate with the importance to safety functions to i
be perfomed ... A quality assurance program shall be established and )
implemented in order to provide adequate assurance that these structures, systems and components.will satisfactorily perfort: their safety function..."
Generel Design Criterion 2 of 10 CFR 50, Appendix A (Design bases for protection against natural phenomena) requires " structures, systems and components important to safety shall be designed to withstand 'the effects of natural phenomena.such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perfom their safety functions...". ,
v 10 CFR 100, Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants (I-Purpose) states, "It is the purpose of these criteria to set forth the principal seismic and geologic considerations which guide,the Commission in its evaluation of the suitability of proposed sites for nuclear power plants and the suitability of the plant
~ design bases established in consideration of the seismic and geologic characteristics of the proposed sites..." Paragraph IV (Required Investigation) states "the investigations shall include the following:
... " Determination of the static and dynamic engineering properties of the materials underlying the site. Included should be properties needed to determine the behavior of the underlying material during earthquakes and the characteristics of the underlying material in transmitting earth-
%./
, _ . . . _ . ~ . _ _ , _ _ _ _ _ . . - - . - _ . - . . _ . . _ , . - - . . ~ . - - . -
l 1
( quake induced motions to the foundation of the plants, such as seismic wave velocities, density, water content, porosity and strength..."
Midland Plant, Units 1 and 2 FSAR, Section 3.2.2.1, " describes the method of identifying' and classifying those plant features designed to withstand the effects of earthquakes, and to which the requirements of ,
Appendix B to 10 CFR 50 . Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, have been applied... structures, systems, and components which are required to support seismic Category I structures, components, and systems are also designed for Category I >
seismic . loads". Taole 3.2-1 provides .a listing of structures , com- ,
ponents, and systems and identifies those'which are seismic Category 1.
Those structures include the containment building, auxiliary building, deisel generator building, service water pump structure and retalning O
walls ana foundations for borated water storage tanks.
The soil foundation work activities for these Category I structures are subject to 10 CFR 50, Appendix B requirements in order to assure that these structures will satisfactorily perfom their safety functions.
Q. 8. When did Consumers first become aware of the apparent excessive settlement of the diesel generetor building?
Consumers first reportea the excessive settlement of the diesel-generator building orally on August 21, 1978 to the Region III, on-site NRC resident inspector. Written notification was made on September 29, 1978 in the form of a 10 CFR 50.55(e) notification of a significant s_ deficiency in construction (attachment 1). This report states that the h
I l
, .~,. - , , .. .- , . - - ., , , - , . . ~ . . - . . _ . . - _ . . .-,...m-
l l
i.
l X diesel generator building and foundations settlement was greater than anticipated at that time (mid August,1978). In fact, the settlement
. values at that time (less than 6 months after the start of construction of the diesel generator building) were approaching the total settlement values for the 40-year life.
Q. 9. Under what circumstance is a 10 CFR 50.55(e) report required?
A. By the terms of. the regulation, a 50.55(e) report is required for each' deficiency found in design and construction which if it were to remain' uncorrected could affect adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the n
. plant and which represents:
. (1) A significant breakdown in any portion of the quality
-.. assurance program conducted in accordance with the requirenents of
[10 CFR 50], Appendix B; or (2) A significant deficiency in final design as approved and released for construction such that the design does not confom to the criteria and bases stated in the safety analysis report or construction permit; or (3) A significant deficiency in construction of or signifi-cant damage to a structure, system, or component which will require extensive evaluation, extensive . redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction pennit'or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function; or I
(4) A significant deviation from perfomance specifications l which will require extensive evaluation, extensive redesign or extensive repair to establish the adequacy of a structure, system, or component to meet.the criteria and basis stated in the safety analysis report or l construction permit or to otherwise establish the adequacy of the structure, system or component to perform its intended safety function.
f% l V I l
1
, . _ . . .~. _ . - _ . . ~ ,
__ . . _ . _ __.. s , - ~ . . _. . . _ . - .. . . , , , . .
. i \
\j Consumers submitted a 50.55(e) report with respect to the soil settlement problem by its letter of September 29, 1978 (Attachment 1).
Several interim reports were subsequently submitted through November 2, 1979. Consumers' initial 50.55(e) interim report (Attachment 1) states that.the event was reportable under 10 CFR 50.55(e)l(iii) which 1s the equivalent of,(3) above - a significant deficiency in construction.
Q. 10. When did you conduct your first inspection at Midland with
,-. respect to soils?
A. An inspection was conducted on October 24-27, 1978 the results of which are contained in NRC inspection report 50-329/78-12;
[V 50-330/78-12 (hereaf ter NRC Report 78-12) dated November 17, 1978
'(' Attachment 2). The purpose of the inspection was to provide Region III
-management'with a preliminary evaluation of the extent of the soils problem based on initial investigative borings, the type of foundation material, review of construction specifications and license commitments.
Items 1(a)- through (f) of that report provided a summary of Consumers 50.55(e) report and infomation Consumers provided while I was onsite.
Items 2 through 8 of that report are the results of my review and observations made during the inspection.
I would like to bring to the attention of the board that the third j
-paragraph of the transmittal letter for NRC Reoort 78-12 and the i inspection summary results therein that indicate that no items of noncompliance were identified are erroneous. At the time of the n
inspection the identified inconsistencies (item 3) and failure to follow
4 9 /D
(%/;) specifications requirements (item 4) did constitute noncompliances. I intended to (and did in fact) conduct further investigations with respect to the soils work activities and these noncompliances. The results of this further investigation of each of these items described in NRC Report 7'-12 d are further discussed in NRC Report 78-20 and are identified as items of noncompliances.
LQ. 11. What actions did the office of ' Inspection and Enforcement take subsequent to the initial inspection of October 24-27,=1978?
.A. We met with Consumers to discuss 'the October 24-27, 1978 inspection and NRC Report 78-12 on December 4, 1978 (See Attachment 3).
Members of the NRC Office of Nuclear Reactor Regulation (NRR) were also
.p
. presgnt as a result of a transfer of lead responsbility that had been executed on November 17, 1978. Bechtel initially addressed the items in NRC Report 78-12. The NRC also emphasized that while attention to remedial action is important, determination of the exact cause is also quite important for verifying the adequacy of the remedial action, assessing the extent of the matter relative to other structures, and in precluding repetition of such matters in the future.
The director of the Region III Office of Inspection and Enforcement then initiated an investigation to obtain information concerning the circumstances of the soil settlement occurrence to determine whether (1) ,
I a breakdown' in the quality assurance program had occurred, (2) whether the occurrence had been reported properly and (3) whether the final
'( v .
, , ,,,.,,-a,,-,-,--- ~ , . , , -ra.-,--c.,r-,, -,,,,,,-n, e-, , ,,,.n.., . . , , , , w,.,, , - . ,-- , ,w~~,n +.---,,,.,,e . - . , ,
.g.
n safety analysis report which had been submitted by Consumers was con-sistent with-the design and construction of the Midland project.
Q; 12. Summarize your preliminary investigation findings.
A summary of the preliminary investigation findings were pre-sented to Consumers on February 23, 1979 at the Region III office. These findings are documented in Attachment 4. In summary, the findings !
related to quality-assurance deficiencies, are:
- The FSAR;did not cor-ectly state the type of fill material supporting safety related structures. This is a violation of 10 CFR 50 Appendit B quality assurance criterion III. (Design Control _)
- .The..FSAR included conflicting values for the settlement of the' diesel generator building founded on spread footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterion III. -
(
, /'
- L (Design Control)
- . The compaction requirement for clay material was not fol-lowed. This is a violation of 10 CFR 50 Appendix B quality assurance criter' ion V. (Instructions, Procedures and Drawings)
- The compaction requirement for sand was not correctly
-translated.into the. construction specifications. This is a violation of i
10 CFR 50 Appendix B quality assurance criterion V. (Instructions, '
Procedures and Orawings)
- Moisture control was .not properly implemented. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI.
~
(CorrectiveAction)
- Soil was not protected from frost action nor removed prior
.to resuming work. This is a violation of 10 CFR 50 Appendix B quality assurance criterion III. (Design Control)
- ~ The root causes of nonconfonning conditions were not ade-quately corrected to preclude repetition. This is a violation of 10 CFR 50' Appendix B quality assur'ance criterion XVI. (Corrective Action) l
- The settlement calculations for the diesel generator l' -building were based on conditions of foundation. type, load intensity and l .: .M
n t i V
soil compressibility other than the actual conditions. This is a violation of 10 CFR 50. Appendix B quality assurance criterion III.
~
-(Design. Control)
- Consumers did not. adequately investigate the extent of the soil problem after the settlement of the administration building footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action)
- Program changes-were not implemented to preclude erroneous
' selection of the laboratory compaction standards (maximum density and optimum moisture content) after the settlement of the administration
~
building footings. This is a violation of 10 CFR 50 Appendix 8 quality assurance criterion XVI. (Corrective Action)
[We subsequently determined that the last two items should not have been listed as quality assurance deficiencies because the adminis-tration building is'not subject to quality. assurance requirements.]
- Co'ncrete material was pemitted to be used in lieu of fill
-material without consideration of the effects on structures. This is a violation of 10 CFR 50 Appendix 8 quality assurance criterion V.
-(Instructions, Procedures and Drawings)
. ,a i
- Personnel directing the soils operation were not trained in
- \ the area of soil work, nor was.a geotechnical soils engineer present on-site as required. This is a violation of 10 CFR 50 Appendix 3 qual.ity assurance criterion II. (Quality Assurance program)
- Inspection procedures were relaxed from original procedural requirements which provided insufficient hold points to ascertain back-fill material .was installed properly. This is a violation of 10 CFR 50 Appendix B quality assurance criterion X. (Inspection)
- The sampling (surveillance) plan was infrequent and inade-quate to verify conformance. This is a violation of 10 CFR 50 Appendix B quality assurance criterion X. (Inspection)
Based on the above findings it was my conclusion and it is my ,
conclusico now that:
l (1) There was inadequate control and supervision of the plant fill.
[ .(2) Corrective action regarding nonconformances was inadequate.
-(3) Construction specifications and design bases were not followed.
l (4) Interface between design organization and construction was inadequate.
l
- ll a
[3'
-(5); The.FSAR. contained inconsistent, incorrect and unsupported
. statements.-
-Q.L13. .Did Consumers respond.to these findings?
l
'A. Yes. Subsequent to the February 23, 1979, a meeting was held !
. . l atsthe Region III . office on March 5,'1979 during which Consumers ,l responded' to the NRC . investigation findings. Consumers response was documented in their submittal which was revised March 9,1979 (Attach-ment 5). During this meeting the NRC Staff reiterated it's concern expressed on December'4,1978' for assessment of the extent of the matter relative.to other structures, and stated that-its concern was not limited .j
~
to' the narrow scope of the diesel generator building but extended to
, pg .various' buildings, utilities-and other structures located in and on the
/ plant fill. . In addition, the NRC' Staff expressed concern with the l implementationofConsumersqualityassuranceprograms.
- , - Consumers March 9,19'/9 response (Attachment 5) f ailed to identify l
-root causes of the quality' assurance deficiencies and corrective actions to p_reclude repetition of these quality assurance deficiencies. l Q. 14. Did the NRC transmit the detailed investigation results to l
Consumers?- !
'A. The" investigation results'were sent to Consumers on !! arch 22, 1979; the details of which are contained in NRC. investigat5on report 50-329/78-20; 50-330/78-20. (Attachment 7). This report indicated-that- !
('
' t, the findings of the investigation' continued to be under review by the NRC i
I L i l
L l
Staff and that upon the completion of that review Consumers would be advised of the enforcement ' action to be taken by the NRC. NRC Report 78-20 contains a more. detailed discussion of the investigation findings l summarized.in response to Question 15 of this testimony.
l Q. 15. What action was taken to detemine whether enforcement action should be taken? I l
- A. On March 21, 1979 the NRC sent Consumers a request pursuant j c to 10 CFR 50.54(f) to obtain additional infomation regarding the ade-quacy of the plant fill ~and the quality assurance program for the Midland site. (Attachment 6). I provided input into the 50.54(f) request, p Question 1 of 22 of the 50 54(f) letter requested infomation regarding Consumers implenentation of-the quality assurance program. On April 24, 1979 Consumers submitted the initial response to Question 1 (Attachment 9). The NRC review concluded that the infomation provided was not sufficient. During a July 18.-1979 meeting, Consuners presented the results of its investigation into the probable cause of the settle-ment problem and the NRC expressed several points of disagreement with these results (see meeting summary dated October 16, 1979, Attachment 13]. On September 11, 1979 the NRC issued Question 23 which contained a i request for additional quality assurance infomation. On November 13, 1979 Consumers Power Co. submitted revision 4 to the 50.54(f) submittals !
which contained their response to Question 23 (Attachnent 14) including f specific corrective actions and commitments for implementation of its
,Q quality assurance program.
U .
I
LQ- V In its; responses to '50.54(f) Question 23, l Consumers identified and
~
discussed the root causes for quality' assurance deficiencies. As !
discussed more. fully'below, information in the response to Question 23:
supports-.the allegation in.NRC's December 6 1979 Order Modifying
~
Construction Permits (Attachment 15) that there was a. breakdown in
. quality assurance.
Q.'16. What action was taken with respect to enforcement? ,
j
'A. .0n December 6,1979 an Order Modifying Construction Permits wasifssued jointly by the'NRC Office of Nuclear Reactor Regulation and the Offic'e of. Inspection.and' Enforcement as a result of. the investigation
.Q
..Q
. -findings'and the' conclusions of the NRC Staff after reviewing responses:
to the 10 CFR 50.54(f) requests of March 21,'1979 and-September 11, 1979.
One of the' bases for the issuance of the December. 6, .1979 Order, was the breakdown in quality assurance with respect to soil activities. (See l paragraph III of the December 6,1979 Order).
As more fully discussed in this affidavit, the facts contained in l
Part II of the December 6,-1979.0rder (including Appendix A) insofar as I they relate 'to . quality assurance, are true.
L li Q. 17... Before discussing what actually occurred at Midland with regard i
!~
to the implementation of the quality assurance progran'in the ji
' soils area, please state the significance of soil compaction and. the factors'which affect soil compaction.
, V .
I I
o- 14
( .A. When soil 'is employed as a structural or construction V)-
material, it must have adequate engineering properties to perfont, it's intended design function without excessive deformation or settlement.
Compaction of soils'is an effective technique for increasing the soil density and attaining'the ~ desired engineering properties of soil
-materials such as acceptable strength, resistance to deformation and resistance to the flow of water. Specifying the attainment of a maximum soil density is an accepted engineering practice for measuring the-effectiveness of the compactive effort.
The density that can be achieved by compaction depends on (1) the soil type.. (d) moisture control,'(3) type of compaction equipment, (4) placement thickness :of the soil layer to be compacted, and (5) the magnitude of the ' compaction effort (for example the nunber of passes of f% the compac' tion equipment). Satisfactpry performarice of the soil can be
- r. . (a) achieved'provided these factors are properly specified and controlled l
during construction.under an effective quality control and quality assurance program.
G. P. Tschebotarioff, author of " Foundations, Retainina & Earth Structures", Second Edition, McGraw Hill, states in paragraph 1-8 l (Special Need for Construction Quality Control) that "In foundation work this need [for construction quality control] is much greater than in any branch of civil engineering.... Constant attention to every detail of I construction procedures is therefore a must in all foundation work.
Above all, continuous competent on-the-site inspection is essential ..."
This illustrates the special character of the geotechnical field, in
. comparison to other construction activities.
l l
b V
I
.. . . . - . . . _ _ . . _ , - . . ~ . - - . , . . , . . . . _ . _ _ _ _ . . _ . . _ __
1 1
I 1
/m'p Q. 18. Identify the 13 quality assurance deficiencies discussed by
\
Consuners in its response to 50.54(f) Question 23.
A. (1)- Inconsistencies between cons'truction specifications and consultant reports.
(2) Lack of formal revisions of specifications to reflect clarification of specification requirenents.
(3) Inconsistency of design basis within the FSAR relating to diesel generator building fill naterial and settlenent values.
(4)' Inconsistencies between the settlement' calculations and.
the original design basis of the diesel ' generator building. ,
(5) . Inadequate design coordination in the ' design of tne duct bank.
(6) Insufficient conpactive effort used in backfill operation.
(7) Insufficient. technical direction in the field.
(8.) ' Inadequate quality' control inspection of placement of fill.
7S )
E'k_/ - '(9) In' adequate soil' moisture testing. . ,
(10) Incorrect soil test results. .
(11) -Inadequate subcontractor test procedure.
(12) Inadequate corrective action for repetitive nonforning conditions.
(13) Inadeq'uate quality assurance auditing and nonitoring of the plant fi.11. work activities.
These itens are discussed below, seriatin.
s
.Q. 19. Sunnarize Consumers and NRC discussion of inconsistencies iden-E tified between construction specifications and consultant reports. (Iten18(1))
t u
_ _ _ _ _ ~ . _ . . _ . . . . _ _
k il
( ,/ A. - Discussion of this quality a'ssurance deficiency is contained in (1) 11RC Report 78-20, pages 9,10,16 and 17, (2) Consumers response to 50.54(f)-Question 1 at appendix 1, page 1 (1 A.1) and page 3 (5 B.1) (3)
Consumers response to 50.54(f) Question 23 at pages 23-6 and 23-7 (sub-section 3.1) and (4) Consumers Answer' to flotice' of Hearing, appendix 1(e) and (f.).
This quality assurance deficiency existed betw'een 1973 through the substantial reduction in. construction during-1973-79 without correction.
Consultant reports'were subnitted by Consumers to the flRC as DSAR attachments. Consumers indicated .that consultant reports were subject to bein3 "nisconstrued as connitaents". Tqe Dades & Moore report, entitled
~
" Foundation Investigation and Prelininary Explorations for Borrow
'taterials, Proposed fluclear Power Plant", dated June 28,1968 was -
t l 'k sulinitted .as PSAR anendment'l and a supplenent to this report dated, p
(1 arch 15, 1969 was later submitted as PSAR anendment 3. Tnis report contained cri,teria relating 'to compaction and frost protection of the foundation naterial which were disregarded during actual construction.
In response to an llRC question Consumers also subnitted PSAR anendnent 9 dated 3/20/70 which states in part, "the design criteria for these Class 'I structures will be nodified to renove all natural sands with a relative density less than 75% and to replace these sands with a controlled backfill compacted in accordance with page 16 to the report
., titled " Foundation Investigation and Preliminary Explorations for Borrou
- taterial Proposed fluclear Power Plant, dated liarch 15, 1969." Since tne Danes and floore report was submitted as part of the application, and was V
s 4t-17 -
/m
\
a (V '
specifically referenced'in Amendment !lo. 9, f1RC considered the designated conpaction criteria to be design connitaents by applicant, m Page 16 of the Danes and floore report indicated the compaction criterion for sands supporting structures to be a nininun 85*. relative density. Contrary to this, Bechtel construction specification C-210 -'
required compaction of sand, to not less than 80'.' relative density., In addition, the 80% relative density criteria was also' not net in numerous cases as will be discussed in Question 28 of this testinony.
Page 13 of the Danes and lloore report indicated "that all frozen so.ils be renoved or reconpacted prior to resunption of operations."
' Construction specification C-210 (" Construct);n for Plant Foundation and y-Cooling Pond Dikes") did not address instructions for renoval or
, ,q, recompaction of frozen / thawed naterial upon resunption of soil work.
, y j
l' V~ '
In addition to the above inconsistencie's Danes &,iloore rep' ort (page l'
- 15) states that "all fill' and backfill materials should be placed at or
. near optinun noisture content in nearly horizontal lif ts approxinately six to eight inches in loose thickness". Contrary to the above, the Bechtel construction specification C-210, section 12.5.3 and C-211. ,
(" Specification for Structural Backfill"). Section 5.2.2 stated, "in no case shall the uncompacted lift thickness exceed 12 inches."
's Consuners states the root cause of these inconsistencies as being that'"During the preparation and early revisions of the PSAR there were no procedural requirenents 'or methods for docunenting the deposition of consultant reconnendations in the PSAR". Consumers apswer of notice of hearing (appendix, allegation 1(e) and 1(f)) " admits to this allegation".
n.
-e- ,g--- , e e-- m - ,n,+v .e ,,,,,.a -+m,s ew .,w,--.w-eevnwr, e,n-i me- ,a ,,,s,r.,s- - --,ma +-
i ' '
iy a The above response fron Consuners supports the NRC finding that .
a:
1 inadequate design control.neasures were established to assure that licenso requirements to'the NRC were translated into construction specifications. Thesel inconsistencies violate 10 CFR 50, Appendix B Criterion-III, Design Control.
l Q. 20. Sunnarize Consumers & NRC discussion' regarding lack of-fornal revisions -ofl specifications to reflect clarifications of specification requirenents. (Iten 18(2))
i A .- Discussion of this qua'lity assurance deficiency is contained in
.(1) HRC Report 73-20, pages 9-14,'(2) Consumers response to 50.54(f)
[e
'V
. 5 Question l'at apper. dix I, pages 1 (t A.2) and page 3 (! 8.2) (3) Con-suners response to 50.54(f) question 23 -at pages 23-8 and 23-9 (sub-se: tion 3.2), and,(4) Consumers answer to Notice of Hearing, appendix, allegation 2(b)(1).
This quality-assurance deficiency existed fron as early as June 1974 through the substantial reduction in soils construction during 1978-79 without correction.
I Bechtel specification C-210 contained conflicting requirenents in
. sections 13'.7 and 12.4 relating to 'the laboratory conpaction standard to be used. Bechtel interoffice nenoranda, telexes and telecons were used in an attenpt to clarify the intent of specification requirenents.
Clarifications provided through these nethods were taken by the user to nodify.;the specification requirenents without a design change or specification change notice to the specification requirenant. Conse-J m ./ .
an,. ,-.i , :,I,,,. ~-,-;. , , , - - - - -.,...a,.n , n., , m-, ., . . . - , , , -~ ~.,-..l.., .,-,, , , , , + . ,
1 19 - j jy l h- :quently. certain activities were not accomplished according to instruc-tions and procedures; specifically, the compaction criteria used for fill naterial was 20,000 foot-pounds (FT-LBS) of energy. rather than a conpactive energy of 56,000 FT-LBS as specified in Bechtel construction ;
specification C-210, section 13.7.
Consumers states the root cause of this quality assurance deficiency as being " Engineering Project Instruction 4.49.1 did not address the use
'of' interoffice menoranda, nenoranda, telexes, twx's, etc. which cight be '
interpreted by the user as nodifying the requirenents of the specifica-tions." (Attachment 14).
Consumers Answer to flotice of Hearing (appendix, allegation 2(5)(1),
"adnits to this allegation".
The above response from Consuners supports the ilRC finding that i
M inadequate procedures for design control were established for the control of specification changes affecting the design bases. The lack of fornal specification revisions 'liolates 10 CFR 50, Appendix R, Criterion V, Instructions, Procedures and Drawings.
l: Q. 21. Sunnarize Consumers and flRC discussion of inconsistencies of design bases within the FSAR relating to diesel generator building fill material and settlenent values. (Iten 18(3))
l A. Discussion of this quality assurance deficiency is contained in (1)_ flRC Report 78-20, pages 6-8, (2) Consuners response to 50.54(f)
Question 1 at Appendix I, page 2 (1 A.3) and page 4 ($ B.3), (3) rN Contuners response to 50.54(f) Question '23 at pages 23-10 and 23-11 u
I
, _,g
- (subsection 3.3) and (4) Cont,uners Answer to Notice of Hearing, Appendix, 1(a). <
.This quality assurance deficiency existed .fron late 1977 until FSAR l revision- 18 dated February 28, 1979.
Consum6rs response states that the FSAR submitted to the NRC (through Anendment 17) contained.certain inconsistencies: i "a. . Tables 2.5-9 and 2.5-14 identify the foundations under the 1 diesel generator building to be cohesive fill. The actual j naterial specified and used was .randon fill, [ defined in FSAR t
' Table 2.5-21 as any naterial free of hunus, organic, or other deleterious naterial also referred to as zone 2 naterial], i which includes cohesive and cohesionless material and concrete. l j
.b. FSAR Subsection-3.~8.5.5.~i.1dicates a settlement of 1/2 inch .
for shallow spread footings -(such as the diesel generator building). FSAR Table 2.5-48 [which is referenced in FSAR ..
sect. ion 2.5.4] indicates a settlenent of the diesel generator !
building of. approximately 3 inches." l G Consuners response continues:
liQ 1
l "The inconsistency between subsections 2.5.4 and 3.8.5 with
- respect to the settlement values-[h inch vs. 3 inches] resulted because the two subsections were prepared by separate organizations-(Geotechnical Services and Civil Engineering),
neither of which were aware of the nultiple display of similar information in the opposite subsection. The inconsistency between FSAR Subsection 2.5.4 and the project design drawing
-(Drawing 7220-C-45) with respect to the fill naterial resulted because at the time of FSAR preparation the Geotechnical ,
i Services personnel preparing the FSAR were unaware, in this .
J l case, of the status of the design drawing prepared by Civil l Engineering."
Consumers stated the root cause of these inconsistencies as being "the control document did not provide sufficient procedural control for preparation and review of the FSAR." (The control docunent establishes procedure for preparation and control of Safety Analysis Reports.)
n l !
4 1
- 21 -
b' V
- Consumers Answer to Notice of Hearing (Appendix. l(a)), . "Adnits to 7
, this ' allegation" that " inconsistencies were identified in the license t application and in other design basis documents".
The above response fron Consumers supports the NRC finding that
. inadequate design control measures lwere established.
These inconsistencies of design bases violates 10 CFR 50, appendix '3, Criterion III, Design Control.
Q. 22. Sunnarize -Consuners and NRC discussion 'of inconsistencies that were identified between the s'ettlement calculations and the original design basis of the diesel generator building. (Iten I 18(4))
O A.-
Discussion of this quality assurance deficiency is contained in ,
' (1) NRC l Report 78-20, pp. 2C-1, .(2) Consumers response to 50.54(f) l Question 1 at Appendix I, page 2 (1 A.4) and page 4 (1 B.4), (3)
- Consumers' response to 50.54(f) Question 23 at pages 23-12 and 23-13 l (subs'ection 3.4), and (4) Consumers Answer to Notice of Hearing, Appendix, allegations 1(b),(c) and (d).
This quality assurance deficiency existed from March 1977 until it was identified during an NRC investigation in 1978.
Consumers reponse'to 50.54(f) states that:
. "Settlenent calculations for the diesel generator building differ from the design requirements in the following ways:
(1) A uniforn load of 3,000. psf was used rather than the 4,000 psf shown =in Figure 2.5-47 in the FSAR.
-p+- *-evg =c y T- w-+gr<W e c ere+v + - , = pc +- T7--*- + - + + erf , ,qp- yC 1pbwgyve-ew. w,TV w dyrup w- e-apry wrr v e-
- e-w*wr e- ww er
l r
'V (2)_-An index'.of .001 was used rather'than the index;of. 003 shown in Table' 2.5-16 in the FSAR.
(3): The calculations assuned a nat foundation rather than a [
spread footing foundation, which is the actual design condition.
and that, "The results of these erroneous calculations were included in the FSAR."
Consumers states. one of the root causes of- this quality assurance deficiency.is::
"Dieself generator building foundation design changes initiated by Project Engineering were not coordinated with Geotechnical Services, as required by the control docunents."
Consuner's Jnswer to Notice of Hearing (appendix, allegations 1(b),
(c) and (d)) 'adnits to this allegation for' the diesel generator building.
- c. . The above response from Consuners supports the NRC finding that
- O inadegoate design control neasures were established to assure proper l'
- design control-interfacas for the diesel generator building. These inconsistencies' violate.10 CFR 50, Appendix 3,' Criterion III, Design Control.
Q 23. Summarize Consumers andLNRC discussion of the inadequate design
. coordination in the design of the electrical duct banks of the
- diesel. generator building. (Item 13(5))
i A. Discussion of this quality assurance deficiency is contained in (1)' HRC Report 78-20, pages 23-24, (2) Consumers response to 50.54(f) question 1 at appendix 1, page 3 (5 A.5) and page 5 (( B.5), (3) Con-b u
-t g -c e,+-" -- v w ~
r - -- w- e
- e.erer "*-g9- -v *-e-+ m-<--+, ---iv-' + ~ ww**-=+r 4e-r,-we - We + m w e-
.c .._ - -- .-.
l l
I l
suners response to 50.54(f) question 23, pages 14-16 (subsection 3.5),
.h~{
and"(4) Consumers-Answer to flotice of Hearing (appendix, 2(a)). I idC-deternired that lean concrete material was permitted to be used in lieu of- soil naterials without qualification as to location.
Consequently, lean concrete material was used around the electrical duct i banks which were to pass through-the foundation of the diesel generator'-
building. This resulted in restricting the free novement of the founda-4 tion which contributed to the differential settlement of the building.
Consumers response states that, 1 "Four vertical duct banks were designed and constructed without i sufficient clearance to allow a relative vertical novenent between the duct bank and the building, and therefore restricted the settlement of the diesel generator building."
and that, s:
"ileither electrical nor civil driaings show how or where to acco.n-plish the transition fron the stub-up size to the underground duct
~
O> ;
i size, nor da they show firn definition of duct size."
. Consumers ' identified the root cause of this quality assurance deficiency as being,
" Failure of the drawings to provide Construction with the infornation necessary to prevent interference."
l Consuners Answer to ilotice' of Hearing (appendix, 2(a)), however, denies that instructions provided to field construction for substituting lean concrete for zone 2 naterial caused differential settlement.
Based on the ilRC review if lean concrete material had not been used ,
around the electrical duct banks, free novement could be achieved between the diesel generator building foundation and duct banks. This lack of free novement did contribute to the lack of uniform settlement. This was l
- denonstrated by the innediate vertical novenent of the structure once it i was freed fron the duct bank.
O V) l
. . . _ . , _ . ~ . , , _ . . , _ . . . . - - . . , . . ~ . . . _ . . _ _ , _ . _ _ _ _ _ . . . - - _ . - _ . _ . . . - .
, c
, .24 - ,
3 This failure to provide adequate procedure'and instructions to j
' assure activities have been satisfactorily accomplished violates 10 CFR
, 50, Appendix B, Criterion V,: Instruction, Procedures and Drawings. ]
Q. 24. Sunnarize Consuners and NRC discussion of insufficient s
.compactive. effort used in backfill operation. (Iten 18(6)) -
/
A'.- Discussion'of this quality assurance deficiency 15 cor,tained in (1) 11RC Report 78-20 pages 9-14, (2) Consumers response 50.54(f) ques-tion 11 at appendix I, page 10 (1 A.1, 3.1) and (3) Consuaers response to 50.54(f) question 23, pages 23-17 and 23-18 (subsection 3.5) -
n This quality assurance. deficiency existed fron'the inception of v.he 19 '
plant'. fill operation in 1974 through the substantial reduction'in soils construction in-1973-79.
Effective compactive. effort depends on the size and type of con-paction equipment, the number of passes of the equipnent and the thick-
.. ness of the soil layer being compacted. Soil specifications and field
~
procedures should have required a " test fill" to demonstrate that a specific piece of compaction equipment with a speciff e nethod (i.e. ,
- number of passes and soil layer thickness) could achieve the required
! in-place density. The in-process density tests would then serve as a continuous verification that the equipment selected and established rathod could consistently satisfy the requirements. The practice of t
qualifying compaction equipnent to a specified method is an acceptable industry practice. The practice of qualifying equipnent was not enployed O
I f I at the liidland site prior to placement of plant area fill activities.
L V L
i
. , , . . . , - _ . . , , , , , , . - . , . . . . _ . . . , - . , _ . . - , _ , . . , ~ . _ . . . - . . . . . - . , _ . . , , _ _ . . _ . . . _ , , , . . _ . .
n (d)
Consumers response stated that, l
l "There are no records available to indicate that the various types l of compaction equionent used for structural backfill wero evaluated or qualified to handle the specified lift thicknesses and that appropriato lif t thicknesses were established for each type of equipnent,"
and that, "Tnere were no field control documents or procedures to define requirements for the qualification of soils conpaction equipnent.
There were no control documents to govern the requirements for control neasures pertaining to soils placement and conpaction."
Consurers stated that the r~" causes of insufficient conpactive effort used in backfill operatic are, (1) "The Quality Assurance Progran requirenent to establish responsibility for measures to control the placenent and conoaction of soils and the qualification of construction equipnent was not adequately inplenented, and (2) " Reliance was placed on in-place test results, or on the IN evaluation of the test results, for evaluating compaction equipnen' .
i,'") Satisfactory soil test results, or evaluations of test results, inplied that adequate conpactive effort was obtained and equipnent capability and fill placenent nethods were not questioned."
Consuners also adnitted that, "Tnese [in-place] soil test results or their evaluations were '.,
error in nonerout cases."
Incorrect soil test results will be discussed below in Question 31.
The above response from Consumers support 3 the flRC finding that inadequate procedures aere developed for the construction of the plant area fill in order to assure that equipment and nethods used were capable of obtaining the required compaction.
The failure to'estahlish adequate procedures to assure use of appro-priate conpaction equipment violates 10 CFR 50, Appendix B, Criterion V, n
Instructions, Procedures and Drawings.
[/')
1
/
Q, 25. Sunnarize Consumers and flRC discussion of . insufficient
^
technical direction in the field. (Iten 18(7))
A. Discussion of.this quality assurance deficiency is contained in
-(1). llRC Report 78-20, pages '24-26, (2) . Consumers response to 50.54(f),
question 1 at appendix I, page 10 (1 A.2 and B.2), (3) Consuners response to 50.54(f) question 23, pages 23-19 and 23-20 (subsection 3.7) and (4)
Co,nsuners Answer to flotice of. Hearing, aopendix, allegation 2(b)(2).
This quality. assurance deficiency existed fron 1974 through the substantial reduction in construction in 1978-79.
t Consuners r9sponse to 50.54(f)' stated:
" Toe Danes & i4oore Report [pg.16] and the Civil-Structural Design Criteria 7220-C-501,-Revision 9, Section 6.1.1 state, in part, !
" Filling operations shall be ' performed ~under the technical super-
.O vision of a qualified soils engineer...."
o l l " Technical direction.and supervision were provided by Field Engineers and Superintendents who were ass.gnad the responsibility for soils placement. The direction.and supervision were not sufficiently employed."
'and that, "The technical direction and supervision provided were not properly deployed to overcone the lack of documented instructions and pro-cedural controls."
Consumers states the root cause of this quality' assurance deficiency as . T l
" Reliance on test results, or the evaluations of test results, and surveillance by quality control instead of providing sufficient technical direction though documented instructions and procedural controls."
Consuners Answer to flotice of Hearing (appendix, 2(b)(2)), "Adnits to this allegation" that soil activities were not accomplished under the y
l r
l-u-
I'
i J
\ . technical supervision of a qualified soils engineer who would verify that all naterials would be placed and compacted in accordance with
. i
~_ specifications -criteria.
The-above response from Consumers supports the flRC finding that technical > supervision by a qualified soils engineer was not provided as required by procedures and instructions. The failure to implement pro- I cedures.to assure sufficient technical direction in the field violates 10 CFR 50, Appendix 3, Criterion V, Instructions, irocedures and Drawings.
Q. ;25.- Sunnarize Consuners and flRC discussion of inadequate quality control _ inspection of placement of fill. (Iten 13(3))
t
'\ Discussion of this _ quality assurance. deficiency is contained in (1) l fiRC Report 73-20,'pages 25-29, (2) Consumers response to 50.54(f) ques-s tion 1 at' appendix ~I, page 13 (1 A.1) 'and page 14 (5 S.1), (3) Consumers response to 50.54(f) question-23, pages 23-21 and page 23-22 (subsec-tion' 3.3) and (3) Consumers Answer to flotice of Hearing (Appendix 3).
L This quality assurance deficiency existed from 1974 through the sub-stantial reduction in construction in 1978-79. i Consuners response stated that,
, " Quality Control inspection of soils work did not identify defi-ciencies which nay have contributed to placement of fill that appears to have densities in place that are lower than those specified."
and that, L U)
L l'
l
, , ~ , , _ , _ , _. _ . _ -..-. _..._.__.._ _ ._ __ ._ _
. . ~ . . . ,
M 9
.: ?
k- ' "The inspection.of- soils was accomplished _ by " surveillance," and did -
-_not require' verification of the controls specified in Specifications ,
7220-C-210 and 7220-C-211.- Soil test'results, or the evaluations of :
L soil test results, were used as the basis for quality verification."
C' onsequently . adequate.qualit'y control verification of the' soils work was'not -accomplished and resulted in the work not being perforned in
- a,:cordance 'with re'qu'irenents to achieve the . required compaction.
Consuners states two 'of the root causes as' being, (1) Too nuch reliance was placed on the-Quality Control Inspector's ability, without sufficiently specific inspection instructions," and (2) "Rel4nce was place on soil test results, or on the evaluation of. soil test results, which were in' error in numerous cases."
Consumers Answer to ilotice of Hearing (appendix,3) adnits "the degree of ins,pection or witnessing was' reduced by. going to a surveillance Q
[ (sampling plan)" and, that "the samp, ling '(surveillance) plan.was inade-quate in ~ that _ it did -not specify conditions or criterja under which there would' be Lincreased _ sampling or a return to 1005 inspection."
. The above responses from Consumers supports the flRC finding that
- adequate quality control inspection was not provided for the verification of soil work activities.
The inadequate quality control inspection of placement of fill j violates 10 CFR 50, Appendix B, Criterion X, Inspection.
- \
~Q. 27. Summarize Consuners and.!lRC discussion of inadequate soil noisture testing. (Iten 13(9))
o y
(Q
]
_, , _ _ __g
J l
D-
.t Consuners identifies.three of the root causes of inadequate noisture testing._as being, (1) " Reliance was placed on the 'infornal incorrect interpretations ;
- of the specification relative to noisture' testing. [
(2) Relianc'e was pla'ced on Quality Control surveillances of '(
noi s ture . tes ti ng. .
(3) Reliance was placed on the' incorrect results of the density tests, or -on the incorrect evaluation of the results, to the exclusion 'of the noisture test results."
- Incorrect soil test 'results are' discussed in response to
- Question 23.
Consumers . Answer to Hotice of iiearing, (appendix, 4(a)) " denies this allegation-to the extent that it' is inconsistent with"'a prior response
, subnitted by Consumers..That prior response is preliminary finding 6 of .
O Attachnent 5. !!y reading of that prior response leads ne to conclude that the requirements .for noisture conditioning prior ts conpaction (as
~
l set forth in- the second paragraph of this answer) was not verified in Ltha.t " prior to. August 1, 1977 there were no noisture measurements made at .
the. borrow area or when the loose fill was placed prior to or during compaction" and after August 1, 1977 "noisture neasurements were made at
-n the borrow area but were not compared to tne laboratory nandards".
Tnis failure to take adequate corrective action to assure appro- I' priate soil noisture testing violates 10 CFR 50, Appendix B, i Criterion XVI, Corrective Action.
t Q. 28. - ~ Sunnarize Consumers and NRC discussion' of incorrect soil test results.(Iten13(10))
N r--- - *w ~,,.,,_,...-.,6 . . , . ,,
31 -
.Q -
o
'A. Discuss'ioniof this-quality assurance deficiency is contained in
- (1) Consumers response.to 50.54(f) Question'1 at appendix -I, page 13 (1 A.3) and page 15-(513.3) and (2) Consumers' response to .50.54(f) Ques-
-_ tion 23, pages.23-26, 23-27 and 23-23'(subsection 3.10)'.
This quality assurance deficiency existed from 1975 through _the substantial reduction'in construction in 1978-79.
~
A' review of the soil test reports indicated fill density tests contain the' following types- of errors:-(1) incorrect soil identification,
-(2) incorrect selection of-laboratory. standard (maxinun density and '
,optinun noisture content) to be used for field control of in-place field density tests, (3) erroneous field density test data for those tests
- abich. indicate the soil to be in excess of _100"; saturated, a physical g inposs,1bility, (4)
- calculation errors, ahd-(5) inproper clearing -of failed test results. (See Bechtel- July 1973 report referenced below.)
- Gased on a Bechtel report to Consuners entitled, " Review Of U.S.
Testing Field & Laboratory Tests On Soils", dated July 1979 !
( Attachnent 11), "Since nore than one half of the test results for j relative density and percent compaction fall outside the possible theoretical conparison limits, it must be concluded that these results 1
are suspect and should not be used alone for acceptance of the plant ared l 'fi l l " . Tne Bechtel report also concludes that as a result of incorrect l soil identification, incorrect selection of the laboratory standard, and erroneous field density _ test data, "there is no rational neans of
'deternining which test results are valid and which are.not."
Consunersiresponse to G.54(f) requests identified the root cause of-incorrect soil test results as, f
f t
v m- -
.wva i ew .-ga+..%m,%--e,- ., r..-,,--- +- -- . wa - ,gy- i,,,-y-,- % at ,or, ,w . uw- e vr - - ' - , -
- 7
y . . . - - . - . -
l 1
1
, l 4 " Technical procedures available to control the testing were inade-N~ #
quate, and the~ technical dire: tion of the testing operations did not I avoid or' detect the incorrect soil test results." l This failure to provide adequate procedure to assure correct soil test results violates 10 ~CFR 50, Appendix 8, Criterion V, Instructions, Procedures"and Drawings.
Q. 29. Sunnarize Consumers and NRC discussion of inadequate subcontractor test procedures. (Iten 13(11))
A. Discussion of this quality assurance deficiency is contained in (1) Consurars response to 50.54(f) Question 1, at appendix I, page 13 (5 A.4) and page 15 (S B.4) and (2) Consuners response to 50.54(f) Ques-
-[ tion 23, pages 23-29,?23-30 and'23-31 (subsection 3.11).
This quality assurance deficiency existed from 1974 through -he substantial reduction in construction in 1973-79.
Consumers response to 50.54(f) states that, "The procedures used for soils testing did not cover the following' activities:
- 1. Developing and updating the family of proctor curves;
- 2. Visually selecting the proper proctor curves;
- 3. Developing additional proctor curves for changing materials occurring between nornal frequency curves; and
- 4. Using alternative nethods of determining the proper laboratory naxinun density where visual -comparison is not adequate."
. Consumers identifies the root cause of this quality assurance deficie'ncy as being,
}
j
fg
'k] '
" Adequate technical procedures for control of the testing were not prepared."
j l
'This failure to provide adequate procedural controls for the soil testing activities violatesL 10 CFR 50, Appendix B, Criterion V, Instruc- ,
i tions,: Procedures 'and.' Drawings.
l 1
-Q. 30. Sunnarize Consumers and NRC discussion'of inadeouate corrective. .
1 a' tion for' repetitive nonconforning conditions. (1 ten 18(12)) !
l A '. Discussion of this quality assurance deficiency is contained in ;
(1)-NZ Report 78-20.pages 17-20, (2) Consuaers response' to 50.54(f)
-Question 1 at Appendix I, pages 21 (5 A.1 and 8.1)..and (3) Consumers- J
. response to-50.54(f) Question 23, pages 23-32 and'23-33 (sub'section 3.12), and .(4)' Consumers Answer to Notice of' Hearing, Appendix 4(b). ,
i This ' quality assurance deficiency existed from 1974 through the j 8
substantial reduction in construction in 1978-79.
s l
Consuners response states that, l "Tnere'were nonconfornances reported which are considered to lie l repetitive. These . include, but are not limited to: CPCo[Consuners]
Nonconformance Reports QF-29, QF-52, QF-68, QF-120, QF-130, QF-147, ,
QF-172, QF-174, QF-199, and QF-203; CPCo Audit Findingt F-77-21 and F-77-32; and Bechtel Nonconformance Reports 421, 686, 693, and i 1005."
l A full description and supporting details of each of the above non-
'conformances are discussed in Attachment 5, item S. j l
Consumers states that the root causes of inadequate corrective l I -a: tion for these ' repetitive nonconforning conditions as being, L j k
[-
)
l ;
.. . . -. -~ .. . . . .. - .
1.. The conditions'under which nonconformances are-considered ~to be repetitive.'are not adequately d~efined in the control documents.
~
- 2. LThe trending activity did not provide tinely responses to repetitive product:nonconforning conditions."- I Consumers' Answer to llotice of Hearing, appendix 4(b) states that the, Licensee admits that' corrective action it initially took with ;
' regard to nonconfornance reports related. to plant fill did not !
prevent nonconfornancesat a later date in the area of' plant fill l construction " .
Consumers reponse supports the i1RC f'inding that inadequate
- corrective action'was taken to assure =that the cause'of the condition was deternined and corrective action taken to preclude. repetition.
This failure to take adequate corrective action to preclude !
~
repetitive' conditions violates 10 CFR 50, Appendix 3, Criterion XVI, Corrective Action.
V Q. 31. ' Sunnarize Consumers and ilRC discussion of ina'dequate quality
) ' assurance auditing .and nonitoring of plant. fil.1 work '
- activities. -(! ten 18(13))
l j A. Discussion of this quality assurance deficiency is contained in I (1) Consumers response to 50.54(f) Guestion 1 at appendix 1, page 21
(, _(G A.2) and page 22.(1 B.2) and (2) Consuners response to 50.54(f) Ques-u l ,
' tion 23, pages 23-34 and 23-35 (Subsection 3.13).
I
- l. .This quality assurance deficiency existed fron 1974 through the
. substantial reduction in construction in 1973-79.
Consuners response states.that, L V(' l i
- . . -. ~
1
- / %) "The Bechtel Quality Assurance Audit and !!onitor Progran did not identify the- problems relating to the settlement. This lack of 4
V identification of' problems by the audit progran contributed to a conclusion that soils operations were adequately controlled."
and that, "In the case of. soils operations Quality Assurance auditing and ;
nonitoring found. that quality-related-activities were being
.perforned as planned, quality verification activities (primarily soil testing) were being perforned, and the soil test .results, or their evaluation, provided evidence of compliance with the established standards. The auditing and nonitoring did not identify the policy and procedure inadequacies."
Consumers identified the root cause of inadequate quality assurance auditing and nonitoring as being,
" Quality Assurance audit and nonitoring was oriented more toward evaluating the degree of compliance with established procedures rather than toward the assessment of policy and procedural adequacy or toward the assessnent'of product quality."
This failure to provide adequate quality assurance auditing and
/~ . nonitoring of the plant area fill violates 10 CFR 50, Appendix G,
'# Criterion' XVIII, Audits.
'Q. 32. ilhat is the cause of the soil settlement problem at the !!idland Plant, Units 1 and 2?
i I
i Since the quality assurance progran in effect fron 1974 through 1979 was' ineffective in' establishing and inplenenting sufficient quality assurance / quality controls to assure proper design, inspection and control of soils work under and around safety related structures I conclude that prior to December 6,1979 tnere was a breakdown in the quality assurance progran.
l l
'~ . ,
The foregoing quality assurance deficiencies resulted in the plant area fill being. insufficiently compacted. This failure to properly com-pact the plant area _ fill was the cause of the soil settlement problem at the Midland Plant, Units 1 and 2.
CONCLUSION The quality assurance deficiencies related to soil construction activities under and around safety related structures and systems arising
- fron improper implenentation of the quality assurance program provide adequate bases to modify the construction pennits by suspending those soil construction activities.
't U
J LIST OF ATTACHMENTS
- 1. September 29, 1978: Initial 10 CFR 50.55(e) Report from Consumers Powe r- Co.
- 2. . November 17, 1978: NRC Inspection Report 78-12,
- 3. January _ 12, 1979: Sunnary of December 4,1978 caeting.
- 4. ~ Februa ry 23, 1979: NRC Presentation of Preliminary Investigation Findings of the Settlement of the Diesel Generator Building.
s i
i
- , _ - , , _. . - . . - _ . - . _ ~ _ . . . . - , . . . . . . . . . . . . _ . . - . ~ - . . . - . . , . . . . . . . , . . . _ . . _ . . _ , . _ .
4
^t
March 9, 1979: Consumers Discussion of NRC' Inspection Facts
- 5. l
_ Resulting From NRC Investigation of the diesel generator building.
- 6. March 21, 1979: NRC 10 CFR 50.54(f) Request Regarding Plant Fill.
1
- 7. March 22, 1979: NRC Inspection Report.78-20.
1
. 8. April 9~,1979: NRC Inspection Report 79-06. l
- 9. April 24, 1979: Consumers Response to 10 CFR 50.54(f), Question 1.
- 10. June 6, 1979: NRC I'nspection Report 79-10.
, 11. August 10, 1979: Bechtel Review of U.S. Testing Co. Field &
Laboratory Tests ' on Soils. -
- 12. October 1, 1979: NRC' Inspection Report 79-19.
13.: October 16, 1979: Summary of July 18, 1979 Meeting.
- 14. November 13, 1979: Consumers Response to 10 CFR 50.54(f), Question 23.
- 15. . December 6,.1979: Order Modifying Construction Permits, l 16. April 16, 1980: Consumers Answer to Notice of Hearing.
l (
- 17. . Professional Qualifications of Eugene J. Gallagher.
.(3v
. _ . . . . _ . _ - ~ _ .. _. _ . _ . _ _ _ . _ _ _. ,
-0'
.? -
.e , _. _ . ..._ . _.... ._..._ .. ... . . . _
.. . . . _ . _ . _ _ _ . . . . . . _ . . . . - - ATTACHMENT 1
~ . e~ p. ., ,., "
. ; ..e . ... .
-'p47 e, ., s . s.*
l
- si..+ w. w. n j
- /m
, 4- t -. r. . .p.
. . . T . i ,' yo , 3,,,s,,,,
\
.t %~~' , ..-
I k 1
~
c.,.,. o, . .. .. w.. .., w m...,;..s ,,, u s, naos . 4, c... i n re s ce ss (
1
,- /
Septe: nr 29, 1978 -
2:ve-; 63 75 / '-
/ ......-
1
\
- er ' l s'
Kr J G Keppler, Regional Director Office of Inspection- and hforcement P.eSien III US Nt. clear Reguistory Co: itsien .
799 Roosevelt Road Glen I' lyn,- II, 60137 _
F.ILL'.!D h'J012AR Pl>JO -
U :I" !.01, D00XII Ito 50-329 W'Z: ::0 2, EC;YZ: NO 50-330 S C.L_2210 0F DIISIL GEiI?ATOR 70UTCATIONS AIO 3UILDIIc In e::ctdance with the req.: ire:ents of 10 CTE 50 55(e), this letter ennstitutes an interi: report on the status of t.he settle:ent Of the
{, diesel generater foundations and building.
".- p' A description of the conditions relative to the settle =ents a;d the investigative actions plar.ned are docu:ented in the enclosures to g th:.s lette. . ,
9 '
b ' An:ther report,' either interi: or final, vill be sent on or before I;;ve:bar 17, 1973.
-.' s
- ,, \ k . m. ..d E i
T.n:lescres: 1) qaslity Assurance Progre=, Management Corrective A:tien Report, MOAR-1, Repor . 2L, datei Se;te=ber 7,1976.
- 2) -stter, ? A Martine: to G S Keeley, 3LO-6576, M"AR-2.,
bteri: Re;;rt $1, dated 9/22/73, with attached re;:rt.
CO: Dire:ter, Cffice of Inspection & Ir. force =ent Att: R. John G Davis, Acting Director, US:30 (15)
., Dire:ter , Offi:e of Manege:ent g , _ .,
I.-f:::stier. and ?r:g.e: Centrol, US:30 (1) ... - a 1; i l J
,^
r
\.
O b wum (ape 1
ATTACHMENT.2
. (-- ,
. ,/%
- !, \.
s
(. (,
iy/
NOV Li 379 :
Docket No. 50-329'.
Docket No.30-330 Consumers Power Company.
ATTM: Mr. Stephen II. Howell
.Vice President 1943 West Parnall Road Jackson, MI -49201 Gentlemen:
This refers to the inspection conducted by Mr. C. J. Gallagher of this office on.Cctober 24-27, 1978, of activities at the Midland Nuclear Plant, Unicafl and 2, authorized by tiRC Conistruction Permits No. CFPR-81 and No. CPPR-82.and to the discussion of our findings with Messrs. J. L~. Corley and T. C. Cookeland others of your staff-at the conclusion of the inspection.
_, ) The enclosed copy of.our, inspection report identifies areas exanined during.the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records,.
observations, and interviews with personnel. (
No items of noncompliance with NRC requirements were identified during the course of this inspection.
.In accordance vi:h S.setion 2.790 of the URC's " Rules of Fractice,"
'src 2, Title 10, Code of Federal Reguistions, a copy of this
~
l .
icteer and the enclosed inspection report will be placed in the
- T?.C's '?ublic Document ' Room, encept as follows. If this report !
contains information that you or your contractors believe to be proprietary, you must apply in vriting to this of fice, within cuenty. days of your receipt of this letter, to withhold such information from public disclosure.' The application must include l a full statement of the reasons for which the information is con- I l sidered proprietary, and should be prepared so t'n at proprietary
! information identified in the application is contained in an
. cnclosure to the application.
I 1
w o ~3 l
- F 78lAlfo/5F (m
~~ -)NPE ,,, . . .
l b"N'd*............................,.............;..............................
f i l' 34? n !
- .sa r.. t+4a 4 *- e ..*a' s . r .' 3 3 %,3 .,e -
.v=..e.- oa..-- - , e *w ai. i
-,.y- m.y.- -,e g . y.--.c .,p --t-r-g
,e ,- - - . - , .ce , - , -.r- . .we- , , ..n. - . . - , ,-, , m. a.i .9-. iw-g-,---
. .. _ m, _ _ - . . - . _ _ - - . . . _ - - . - _ _ . . . .- _ . - . _ - _ . . - _
4 N
i
'; L e a 'r P
- 2- A0V 1'i . 378 -
Tonsumers Power Company' I , .
- I fi t,'e vill gladly discuss any questions you have concerning this !
'I
- l. inspection.
n; Sincerely,
.t.7-1 e .
4
'l .
7 R. F. Heishman, Chief '
Reactor Construction and E.ngineering Support Branch
'.'i.
t
. t '.
Enclosure:
- IE Inspection
-[ Repores No. 50-329/78 l.
3 = and No. 50 330/78-12 u
f ~
- i. cc w/ enc 1:
' Central-711es I [
.J .
-l I Reproduction Unic NRC.20b PDR-i
. Local PDR:
USIC-
.U
- TIC- *
'.', - . Ronald CaJ1en, Michigan Public
'i Service Coc. mission -
Dr..Waync.E. Uorth
.Myron' M. Cherry,> Chicago'
.1
- t -
k-t )
-} i i
4 s-k' 1
i
}!
1i .
/.
h i 3III
<. 2. .//. . N
. .l R..I.......
- ~ , .
u ,: c r i, i .R.13. .I.>.. . . '. .. . . .R.I.I. ,I..4 . . . . . . .7 . .
. . *.R.I. .*,I,' 0
,I b .,. , . . L . .
r-
, _ 4 W. . 5;essard Hai3) .at Vandel [ Cook d-*-- - *-- ---
-l Ga ---
sw.wr>: .... ira.5.h..si/.bk... ....................r------#
..r.......
e
- A t > L .1.1. [.1.!. i.h.3. . ... . _I . . .. . . . . . . . . . ... l .
M2,#' ** 2 ! j $ " 3 *,.".*. ) 71 il f 74 2 6" *.I ) S)
,g 17,gggyggf74 gF.Ae4Q##4(
49 ?d* ?$) 347 e
+ , ,, + , . . - , . . - .- ,...,.,%.e,u._...... .,,...... .. .,% ~ # ,.m.m...w.-,,,,~,,,.-,,,.,,,4m,,,,...., .,4 . . e cw . c r . ,mm , -,, .n.,-
^
{: '
(
C U.S .L NUCLEAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ESTORCDIENT-REGION III Report No. 50-329/78-12; 50-333/78-12 Docket Noi.50-329; 50-330 License No. CFPR-81; CFPR-82
. Licensee: Con.sumers Power Company 1945 West ?arnall Road
-Jackson,.MI 49201 Facility.Name: Midland Nuclear Power Plant, Units 1 and 2 i
Inspection At: . Midland Site, Midland, MI Inspection Conducted: ' October 26-27, 1978 ,
!?. cb & as,< r - r[,. '/[' ",/ 4 6
-Inspector: E..J.Ca/lagher Vf( .!D4-A.s fr A -
Approved.By: 'R. L. Spe'ssard, Chief "b'
- v
-(
l Engineering Support Section 1 Inspection Summarv Insoection on October 24-27, 1978 (Report No. 50-329/78-12; 50-330/78-12)
. Areas Inspected: 10 CFR 50.55(e) report concerning settlement of diesel generator foundation and building; backfill specifications and quality control'instructi:ns; preliminary soils test results from core boring ilavestigation'; site implementing procedures; performance of soils testing; and ' diesel generator building and pedestal de*. ails. The inspection involved a total of 36 inspector-hours onsite by one NRC inspsetor.
Results: No items of noncompliance or deviations were identified.
O Q
3)vt6 . 0F
?iflSITO/60 7]ndnk,b .
~
7-o . . . _ _ _
Mu*@S4
^
ATTACHMENT 3 3
j- ~
[g %,'
umtEO sTATEI NUCLEAR REGULATORY COMMISSION
. C: j .M.!d ,*tj W ASW.GTON, O. C. 20565 4, v , f JAN 12 IS?9 :
... 1 -
t -
- DOCKET NOS. 50-329 ,
50-330 APPLICANT: -Consumers Power Company FACILITY: Midland Plant, Units 1 & 2 .
SUBJECT:
SUMMARY
CF DECEMBER 4, 1978 MEETING ON. STRUCTURAL SETTLEMENTS On December 4, 1978, the NRC staff met in Midland, Michigan with Consumers. Power Company (CPCO), Bechtel Associates', and consultants in geotechnical engineering to discuss excessive settlement of tne Diese1' Generator (DG) Building and pedestals, and settlement of other seismic Category I structures. These technical discussions followed ,
a site tour on Decemoer 3, 1978 during whicn the NRC staff observed eacn of these structures. Attendees for tne tour and technical cis-cussions are listed in Enclosure 1. Enclosure 2 is the agenda used during the technical discussion.
- 1. Backcround
Pursu' ant to 10 CFR 50.55(e), CPC0 notified Region III of the Office of Inspection and Enforcement (ILE) on Septemoer 7, l'973, nat settlement of. the Midland DG Building foundation and generator pedestals was greater than expected and that a sofis ooring program had been started to determine the cause and extent of the problem. An interim status report was provided I&E by CPCO's letter of September 29, 1978. I&E conducted inspections on'this matter on October 24-27, 1978 and issued inspection report number 50-329/78-12; 50-330/78-12.
t 2. History _
l The Bechtel representative identified the Category I structures 7
and the type of material supporting the structure:
l a. Containment - Glacial Till j .
l
- b. Berate,d Water Storage Tank - Plant Fill
- - c. Diesel Generator Building and Pedestal - Plant Fill
- g Auxiliary Building - Part Glacial Till & Part Plant Fill 7 i .d. 1
- e. Service Water Intake - Glacial Till (Completec portion Only)
- Plant Fill (Small portion yet to ::e
'O ! '
constructedi l l
)
W " '
9
% [f f N & kyk Of & E f Dlo16 C M g L --
C
("N /'N pn KiQy %
e d Do UNITED STATES
' / *) g ' ,g [
NUCLEAR REGULATORY COMMISSION -
- 7. r. t WASHING TON. O. C. 20555
- <M !n !
~
!U a, ../ NCV 141978 c
Docket Nes: 50-329 50-330 2 hTMORANDUM FOR: Steven A. Varga, Chief, Light Water Reactors Branch No. 4, DPM l ,,
FROM: Darl Hood, Project Manager, Light Water !
Reactors Branch No. 4, DPM '
j t'
SUBJECT:
FORTHCOMING MEE'"ING AND SITE VISIT i ON SETTLEMENT OF MIDLAND STRUCTURES i Date 6 Time: December 3, 1978 -
1:00 p.m. .;
December 4, 1978 -
9:00 a.m. ?;
Location: Midland, Michigan r Plant Site
Purpose:
To discuss and observe Ik settlement of the Diesel i3 Generator Building and i other structures. 3 fS .
!,'s)
Participants:
NRC L. Heller .
D. Gillen -
D. Hood
- R. Cook (Site) y.
A. Hafi:
Consumers Power Company L
' ,! 0-G. Keeley, et. al. .
) c.
I
[J oV *i
. m .:
Darl Hood, Project Manager 3 Light Water Reactors Branch No. 4 >
Division of Project Management " -
Enclosure:
?
Agenda ,
.* o i
'! 3 cc:
See next page k "-;.
r .
l '
XL
\ ?&b.$
d;M; i.}
(
D ~%
'f"
% WAD @
oy Q
97g Lih m35Esss h M wm m m mm* d #
. - . . . . _. .- . . - . -- - . -. . - - - _ . . - . . . . . . ~ _ ..
. .. - . . - . - . - . . . ~ - . _ - . - - . - , . . - . . _ . - .
. \
ATTACHMENT 4
)
i -
, , I i
U.S. NUCLEAR REGL" ATORY COW.ISSION OTTICE OF INSPECTION Aht DTORC E li REGION III !
C f PRESEh7ATICS OF IN's*ESTIGATION TINOIN05 0F TdE SETTLIMENT OF TdI DIESIL GENERATOR SUILDINO
-Aht PLANT AREA FILL fr -
. l CONSW.ERS Por:.R COMPANY '
MIDLAND NUCLEAR, POTS.R PLANT' 4 UNITS 1 AND 2 I
J l TISRCARY 23, 1979 1
l I I l 1 l
l
!- j i
i l
< 1 l
1
4 6 '
e
,s (
CONTENTS >
- l. Scope of Investigation
,2 . Identification and Raporting of the Diesel Generator Building Settlement
.3 . Review of PSAR/FSAR Comrnitments <
. 4. Ef f ects of Cround Water on Plant ' Axea Fill
- 5. Compaction Requirements for Plant Area Fill 5
- 6. - Moisture Control Requirements for Plant Area Till ;
- 7. Subgrade Preparation for Plant Area Fill '
- 8. Nonconformance Reports Identified
- 9. Settlement Calculations for Plant Area
- 10. Settle =ent of Administration Building Tootings
- 11. Interf ace Between Diesel Generator Building and Electrical Duct
/ 1anks 5
'- Soils Placement and Inspection Activities 12.
- 13. Inspection Procedures for Plant Fill 14 Final Conclusions I l l
s l
1
\ !
l I' l
b - - -- . . . . . . . . . . - . . . . .. . . . . . - . . . - - . . - . - . . ~ . , , . - . -.. . , - . . . . . . .
t e, ,
[ 1. Scope of Investigation
. \
. The NRC Region.III of fice performed an investi;3ation to obtain ]
information relating to design and construction activities affecting the Diesel Generator Building foundation and plant area fill and ;
the activities involved in the identification and reporting of the s e t tl ement of the building.
- The investigation consisted of 240 onsite hours by three NRC inspectors and included examination of pertinent records and proce-dures and interviews with personnel at the Midland Site, the -
Consumers Power Company offices in' Jackson, Michigan, and the Sechtel Power Corporation of fices in Ann Arbor, Michigan.
h i
^% .
P k
3
-/j 2. Identification and Reporting of Diesel Generator Building Settlement
/ 5 Inspection Facts
- Bechtel surveyors first noticed unusual settiament on July 22, 1978, while perf orming routine survey measurements.
- The result of the survey with unusual settlement was routinely transmitted to Bechtel Engineering.
- Tield Project Engineer instructed surveyors to recheck survey and perf orm survey more frequently. The building was monitored
. for about one month.
- Apparent settlement continued and when it exceeded the values presented in the TSAR, a conconformance report was prepared
. on August 18, 1978.
On or about August 21, 1978, the NRC Res;Jent Inspector was informed of the settlement.
- Af ter an exploratory boring progra= began on August 25, 1978, and preliminary data indicated deficient material, CPCo reported the inciden: under 10 CFR 50.55(e).
- Formal notification was made on Septe=ber 29, 1978.
) Conclusion
(
CPCo, After preliminary evaluation of cne safety i=plications, notifted the NRC in accordance with 10 CTR $0.55(e).
Findine Compliance of 10 CTR 50.55(e), reportability requirements.
l l
7- s s.
i l
I
- 3. Review of PSAR/FSAR Commitments 7
Inseeetion Tacts TSAR Tables 2.5-9 and 2.5-14 identified the type of foundation material to be controlled compacted cohesive (clay) fill.
- Sechtel Design Drawing C-45 (class 1 fill material areas) specify Zone 2 random fill as any material free of organics with no restrictions on gradation.
FSAR Tigure 2.5-48 (estimated ulti=ates sectiements) indicates the Diesel Generator Building to be approxima:ely 3 inches.
~ TSAR See:1on 3.8.5.5 (structural accep:ance criteria) indicates shallow spread footing foundation settlemen:s to be 1/2 inch or less on compacted fill. The Diesel Generator Building had a shallow spread footing founda:ien.
Conclusions
- a. The TSAR did not accurately state the design basis or type of fill material supporting class 1 structures.
- b. 'he T TSAR included conflicting values for the set:lement of the. Diesel Generating Building founded on spread footing, h O Findint
- I %,,
l Item of noncompliance with 10 CTR 50, Appendix B, Criterion III (design control); failure to translate design basis as specified in the license application into instructions, procedures or drawings.
l l
l
{
l l
i i
\
G L
l l
~
, - i O 4 .. Effect of Cround Water on Plant Area Fill
.-( Q . Inspectica Facts 1
- PSAR,. Amendment No. I and Dames and Moore report on foundation l investigation indicates'a planned drainage system to maintain I the ground water level in the plant fill at elevation 603. I
- PSAR Anendment No. 3 indicates this underdrainage system has l been eliminated and the ground water is assumed to rise concurrently with the cooling pond to elevation 625.
- Bechtel consultant (Dr. Feck) has indicated that small changes in moisture content of the soil vill probably result in increased compressibility.
Conclusion It has not been fully determined whether the full effects of satur-ating the fill was taken into account in the design basis.
Findinz Unresolved matter pending licensee evaluation on the effects of permitting the ground water to rise in the plant area fill.
,. \ ,
i v
e 5-x f 9 -4we*r--y -e= m .,,y.y y ,. _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
o l 1
. N_ D) 5. Compaction Raquirements f or Plant Area Fill Inspection Facts l l
PSAR Amendment No. 3 required the following compaccion: I Clay - 100% of manimum density using a compactive energy of 20,000 f t-lbs (equivalent to 95% of maximu= density !
using ASTM 1557 Method D vich 56,000 f t-lb energy).
Sand - 85: relative density.
Bechtel Specification C-210 requirements:
Cisy - 95* of maximu= density using ASTM 1557 Method D (sace as PSAR)
Sand - 80: relative density (less than PSAR)
Bechtel implemented require =ents:
Clay - 95* of maximu= using Bechtel Modified Test Me thod using 20,000 ft-lbs (less than that required by the PSAR and Specification).
San'd - 80 relative density (less than PSAR required but me
/'~'N Specification require =ent).
Cone'lusions. , ,
- a. Bechtel translated PSAR compa,ction require =ent for clay in construction specification, however, failed to follev require =ent.
- b. Lechtel did'not translate PSAR compaction requirement for sand to construction specification.
Finding Ite: of nonce =pliance with 10 CFR .50, Appendix 3, Criterien V (procedures); failure to implement construction specification requirements.
-s l \s
[ 1
\s /
1 l
1
4
- 6. Moisture Control Raquirements for Plant Area Till g D Inspection Tacts
- Bechtel Specification C-210 required moisture conditioning in the borrow areas such that the moisture prior to compaction was within plus or minus 2% of optimum moisture content.
CPCo and Bechtel QA identified that che moisture control was not being implemented prior to compaction on July 22, 1977.
- No association was made with a laboratory compaction standard (i.e. optimum moisture-saximum density curve) prior to compaction.
- Tree July 22, 1977, until June 1,197C, Bechtel project engi-necting failed to provide adequate direction for control of moisture content.
Conclusion-Tor all practical purposes, moisture control was not imple=ented prior to the settlement failure of the Diesel Generator Building.
Findinc Ite= of nonce =pliance with 10 CFR 50, Appendix 3, Criterion XVI (corrective action); failure to take corrective action in a timely b manner.
U. .
6
- 1 ~-
O
(
4
,._--,--,-,-,,o_ , , y,- y- ,,, , , , , ~ - , . . . - - , . , - , _ ry-m-. , , - - , , , , , , , . - - , . , . . - p
f -'.
Subgr'ade' Preparation of Plant Area Fill
-. 7.
.k' Inspection Tacts
- PSAR Amendment No. 3. and Dames and Moore foundation investi-gation. report indicated that if the construction schedule required foundation excavation. to be lef t open during the winter that at least 3 1/2 feet of material be excavated before resumption of soils work:or that same caount of cover material remain in place.to prevent softening of subgrade soils due to frost action.
Bechtel Specification C-210'enly prohibited placement of soils frozen surfaces but did not include provision for frost protection or, removal of material prior to. resumption of work.
- Correspondence . indicates that approximately only 3 inches of frozen / thawed soil was removed prior to resumption of soils work.-
Conclusions l' a. PSAR requirement was not translated into the specification for soils work.co preclude placement of soil over subgrade effected by frost action,
- b. Soil was not protected f rom f rost action nor removed prior to resc=ing work.
/
ms .
e b( Findint Item of noncompliance with 10 CTRL 50, Appendix 3, Criterica III
-(design control); failure to translate require =ents into instre:tions or' procedures.
- 8-I t
,f'%
l I
! \s i
l l
l
~ , , , ..m., ,,,,,,..,~..._.._---,m, ..,-,.,-s.,-,,,,.- ,.-w..-w.,...,-.... ..,,.,.-,.mm-..- ...__m~...-- -.,. .~- - '
~~
- v . _
f~'N 8. Nonconformance Reports Identified,
- kN- Inspection Teets
- CPCo and Bechtel QA identified reperced nonconforming conditions in the following areas of soils work:
Tailing compaction tests due to using incorrect maxinu: lab
~
density.
Moisture control tolerance.
.Inadequata inspection.
Violation of lift thickness.
Gradation tests not taken.
' Gradation requirements not me t . .
Inadequate test frequcncy.
Foresen directing soils not f amiliar with specificatien re quer ement s.
- The most frequently used engiaeering disposition was to accept "use as is" with .or without sound engineering basis, i Conclusion -
The root of the deficiencies was not' adequately cc:rected to t
preclude continued degradation of the quality of a safety related activity.
TLydint Ice: of nonce =pliance with 10 CTR 50, Appendix 3. C;iterion XVI' (correcti e action); f ailure to take adequate corrective action to preclude repetition.
I
! l 9-l l
rw i l
t-
~
- 9. Se c tiement Calculations for Flant Area Fill j Inspection Facts
- Bechtel settlement calculations for the Diesel Generator
. Building were based on a uniform mat foundation with a unifor=ily distributed load intensity of 3000 psf.
- FSAR Section 3.8.4.1.2' (Diesel Generator Building) ledicates the foundation to be a spread footing type with a load intensity
'f o 4000 psf with independent diesel generator pedestal.
Berated water storage tanks are supported by a circulst spread footing. The settlement calculations were based on a unifor:
circular sat foundation. ,,
- FSAR Table 2.5-16 indicates the soil compressibility parameter to be 0.003 for the soil between elevation 603 and 634 Settle-ment calculations assumed an index of compressibility of 0.001.
Conclusion The estimated settlement values for the Diesel Generator Building and borated water tanks shown in FSAR Figure 2.5-43 were based on conditions that are at variance to existing conditions such as foundation type,- load intensity and soil compressibility.
Findinc I .D k Item of noncompliance with 10 CTR 50, Appendix B, Criterion III
\- (design control); f ailure to translate design basis as specified in the license application into instructions, procedures or drawings.
i I
l i
. /- B
. . . _ . ._ __ .. ,.~ _ . . _ . . , . . . _ _ _ . _ _ . _ _ _ _ , . . . _ . _ _ . . _ . . . . _ . _ _ _ _ , . . _ . . _ . , _ _ _ _ _ _
- 10. Settlement af Adstnistration Building Footings
's Inspection Facts
- Administration Building was originally supported by Lone 2 random fill material.
' Administration building foundat!.on material was tested to the same compsetion requirements as class 1 fill.
- Administration Building foundation material was placed similar to class 1 fill; by hand held and motorized equipment.
- ' bechtel report identified basic cause of ad=inistration failure as being due to the result of repeated erroneous selection of laboratory compaction standard (i.e. , incorrect selection of moisture-density standard f or soil material' being compacted) .
- Only two borings were authorized to investigate the extent of the deficient soil outside the Ad=inistration Building area.
Ad=instration f ailure was then considered to be local condition.
- CPCo management (Corporate Project Engineer and Manager) were not properly informed of the Administration Building settienent.
. Conclusions l
/' ) , a. CPCo did a . adequately invescigate the extent of the soil l ( ,,) deficiee. in the rest of the class 1 fill. .
- b. No program changes were implemented to preclude the continued erroneous selection of the laboratory compaction standard. .
Finding Item of nonceepliance with 10 CTR 50 Appendix B, Criterion IVI (corrective action); f ailure to take adequate corrective action to identify the extent of the deficiency nor preclude repetition.
l
/~'s
! \
b
J,
/
- 11. Interface Between Diesel Generator Building and Electrical Duet Banks r'\' l Inspection Tsets ]
l Bechtel Electrical Design Drawing E-502 includes a detail to
- i provide separation betveen the duct banks and diesel generator l footing (i.e., styrofoam bond breaker to permit settlement of the Diesel Generator independent of the duct ban;k.s).
- Bechtel Construction Drawing C-45 permits the use of rando= fill Zone 2.
~
- Correspondence fro: Bechtel engineerng to field (December 27,197!.)
petuits the use of lean concrete as replacement for Zone 1 and 2 material.
~
- 3echtel field used concrete around electrical dus; banks under the diesel generator footings.
Conclusien Due to permitting the use of concrete indiscri=inately as rando: fill the unifor: settlement of the Diesel Generator Building was restricted in the areas of the duct banks.
Hedint b Ite: of nonec=pliance with 10 CTR 50, Appendix 3. Criterion V l g"')g (procedures); failure to provide adequate. instructions to preclude the use of a material that vould cause differential settle =ent. . .
r%
.u-
~* . -
--g 12. Soils Placeeent and Inspection Activities s
_ Inspection Facts
- Bechtel Design criteria C-501 requires soils operations to be performed under technical supervision of a qualified soils engineer to verify all materials are placed and compacted in accordance with criteria.
' 4.
- Labor foreman were directing soil operetions relative to test locations, test frequency, compcetion and moisture.
' Bechtel field and' QC inspectors were rarely in the areas where soil operations took place.
- Accuracy of test locations were a chronic problem.
- ' Moisture'was added to the soil after compaction if moisture test failed.
, conclusion Personnsihirectingthesoilsoperationwerenot trained in the area of soils work nor were they considered to be qualified soils engineers.
Finding s
Item of noncompliance with 10 C7R 50, Appendix 3, Criterion II .
N (Quality Assurance); failure *to provide training to personnel ,
l perfor=ing safety related activities.
I l
d f-s k
l l
4
,.v,..e + rw-+- ,-9 , ,- , , + e ., -
,w. < ,er--.-
1
- 13. Inspection Procedures for Plant Till 5
. Inspection Facts
- 3echtel Procedure C-1.02 (compacted backfill) was written as a replacement for Procedures C-210-4 and C-211-1.
1 Procedure C-1.02 relaxed certain inspection point to survetl-
. lance only. For example:
Inspection Procedure -
Activity C-210-4 C-211-1 C-1.02 Ma:arial Tree of Organics -
I S(V)
Material Moisture Conditioned S I S(V)
Material Not Trozen - I S(V)
Compacted to Density W S S(V)
Lif: Thickness Required W I S(V)
Conclusions
- a. Inspection procedures for soils work were relaxed from original procedural requirements to leaving insufficient mandatory hold points to ascertain backfill materials were installed to requirements.
- b. It was ascertained that surveillance was infrequent and inadequate g to verify conforsance. ,
Finding -
Iten of nonce =pliance vich 10 CFR 50, Appendix 3 Criterion X i (inspection); f ailure to provide adequate inspection plans.
l t
%) .
l l
1 l
l . .
l
. .= .. ..
. . -_ - _ . . _ _ , . . . . . _ , , . - . _ _ , . . . . . _ . ~ . . _ _ . . . . - _ , . - - . , . . _ . . . . . _ . . _ . . . _ _ . . . . _ - . . , . - . . ~ . . .-
1
.a l
,e I.
- 14.
- Final Conclusions
- There was inadequate control and supervision of plant fill material placement.
- Corrective action regarding noncomformance related to plant fill was either not taken or was inadequate.
- Certain design bases and construction specifications were not followed. ,
- Weaknesses exist in the interf ace between various components within the construction contractor's organization.
- -- The FSAR contains inconsistant, incorrect and unsupported s ta t ements .
- Note: These are the conclusions of the RIII investigation as of February 23, 1979. Final conclusions of daC with respect to'the technical adequacy of the foundations is under consideration by the NRC staf f.
\
i 6
e 9
1 1
1^
l ATTACHMENT 5 PRELIGRY Revised March 9, 1979 l
l Cv^.'*'cw c0~
- '.D =.^'6'w'.-
V "v^..o'.'
v o.
DIa pt mata .C..'W'C Ovd30.
p, p J .i .~.w .. .. -- w 1.ic."L .mA C A . e.i . n7.a0 a y.- - Om v.w a. e.1m.I C.;.
are bc NQ w m.
1 **6 V 7. .C s.n e1...
m;; a m.
.e .av 4. . / w . w .
- n sr_. a- su- Gr : e.02, lm. m1..ov m..~.= .i. , . s t
i Decket No. 50-329 Docket *o. 50-330
.. ..- _ . . , _ . . . _ - - . . _ . . . . . . _ _ . . - ~ . . . . _ . . _ _ _ . _ . . -- _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ ~ _ - _ _ _ _ _ . .
f lA '~ '
- NRC PRELIMI. NARY FINDIIC 2 -
i& f
- 2. - Identification and Reporting of Diesel Generator Sullding Settlement Discussion of trRC Inspection Facts (from the Preliminary NRC Report)- .
On July 7,1978, Construction Survey personnel noted diffleulty in closing a' level circuit:when leying out' survey control carkers for continued con-struction of the diese1 ' generator building. A survey check ves cade asuinst existing. survey. control carks .in the building on July 10, 1978 and a degree of settle =ent was noted. .. On July 2L,1978 the first for=al 60-day settle-ment reading required by Specification 7220-C-76 fcg the diesel generator e
pedestal vas taken. Bechtel Surveyors, in . processing this data, noticed a : larger than anticipated ' settlement.. The processed survey data was
-transmitted to-Project Ingineering on July 26, 1978. The' cembined re-suits of_the-July 10, 1978 and July 2L,1978 readings prompted Construction Survey personnel to'tenitor the building settle =ent in excess of Specifica-tion 7220-C-76 frequency require =ents. On August 21, 1978 a Construction Survey check of the elevation of the northeast anchor bolt tcp en the
- eastern diesel generator pedestal shoved a settle =ent in the range of the esti=ated ultL: ate value in FSAR Figure 2.5-43. .
A Bechtel nonconformance report was issued (NCR lL82) to docu=ent the
- August 21, 1978 Construction survey readings en the anchor bolt. As a result of NCR'lL82, all construction activities on the diesel generator
- 's - building, except for reinforcing steel installation, was halted. On August 21,fl978, CPCo advised the URC Resident Inspect 0
- cf the settle-
, h_
\~. .
ment , condition. This notification was for infor:stion cnly.
An exploratory soll boring progrs= vas begun on August 25, 1978. An evaluation by Project Insineering of prell=inary boring data cade on September 6,1978, indicated that the settle =ent condition was reportable under the. require =ents of 10 C7R 50.55(e)- .
On September .7, CPCo made an oral 10 C7R 50 55(e) report to the NRC.
CPCo sub=1tted vritten 10 CFR 50 55(e) interim reports to tne tiRC en
'Septe=ber 29,'1978; November 7, 197S; December 21, 1973; January 5, 1979; and February 23, 1979.- The next interi: report is due to be submitted by April 20, 1979 A subsequent error has been noted in Revisien 18 to the TSAR dated 2/79 The error is that Revision 18 is in conflict with the infor:stion given above. --Revision 18, derived .from the 50 55(e) report dated Septe:ber 29, 1978, states that "the diesel generator building settle =ents were noticed to exceed enticipated values in July,1978." The " anticipated values" referred to in this repert vere not the "esti=ated ulti=ste settle =ent" ;
values given .in . TSAR Figure '2 5 L8. Instead, these " anticipated values" '
vere cerely values of settlecent that were greater than the a=0 tnt Of settlement which would have been expected under usual conditions for the elapsed time. The pre;erer of the FSAR Revision erroneously ce=bined '
- these two unrelated values.
!m-\,
1 of 2
~
i y -- w- -y g-- $ ( ,%y+ge w wg+w-gwy-www"-'y-3,yP19- g- g*-r4 W yetv-y rvet-Y'**'r-M V1 'S99 $P WtW- VD*WFW9w we
- W v'vW'T R1Wr ' ' **O W 3Y
- 2. Identification and Reportin6 of Diesel Generator Building Settlemert (Contd)
Concluslen CPCo gecplied with the 50 55(e) reportability require =ents.
4 e
8 9
6 4
l
\
i r
i 2 of 2
f J
/ \
N NRC PPILIMINARY FINDI:G 3 3 Review of PSAR/7SAR Con =1t=ents Discussion of NRC Inspection Facts (frc= the Prell=inary NRC Report)
FSAR Table 2 5-9 provides ce=paction criteria and zone designation both of which are design bases. : Inadvertently o=1tted frc= this table was the nu=ber "2" in the . column used for " Zone Designation for the " Support of Structures." Also inadvertently o=1tted vere the words "and sand" in the colu=n' used to designate the "Soll Type" for the " Support of Structures."
FSAR Table 2 5-10 provides a definitien of Zone 2 =sterials. These
=sterials were used consistent with the recc==endations contained in the Da=es and Moore' report included in the PSAR. FSAR Table 2 5-1L sr--* rices contact stresses, esti=sted bearing espacity and facters of safety for the ,
supporting soils given in the table for each structural unit. However, sece of these supporting soils specified in Table 2 5-ik vere intentionally not the sa=e es' the design bases soils described (or intended to have been described) in Table 2 5-9 The supporting soils specified in 2 5-lL vere those used for the conservative calculations given in that table.
FSAR Table 2 5-9 vas revised to- correct the inadvertent c=1ssions and Table 2 5-ik .vas revi;ed to reflect the design bases centained in the PSAR
-(as translated Linto the actual desigr.) rather than to reflect the =aterial p ,,e used for calculational purposes.
\
L i
! 's ' The settle =ent information en spread footing found in Section 3.8.5 5 of l the PSAR was a carryove-. of a prell=inary esti= ate given in the PSAR.
! The information regarding settle =ent found in Section 3 8 5 5 of the FSAR is not applicable to the as-built configurations and conditions cf the diesel generster buliding and has been ell =inated frc the FSAR in Revision 18. The settle =ent predictions intended for the diesel generster
' building are found in Figure 2 5 LS of the F3AR.
Concl'usiens
- s. The FSAR accurately states the design bases or type Ecf fill =aterial supporting Class i structures except for the inadvertent c=1ssicn of the nu=ber "2" and the words "and send" in Table 2 5 9 Regardle ss of the c=1ssicns, however, the proper design basis was carried
, through to the detailed design.
i l
The presentction of 7 GAR Table 2 5-li was nos as clear as it could b.
have.been with regard to the use of the entries .'n the " Supporting Soils" colu=n and has since been revised.
- c. The presentation in FSAR Subsections 3 8 5 5 was net as clear as it j could have been to distinguich it frc= the different' infor=a:1cn presented in FSAR Figure 2 5 h8 and has been ell =inated.
l- .O .
l s_ ,) '
I
! 1 of 1
. -- .- , .~ . - . . - - . . , , . .. . --
I l
-cN NRC PRILDCIARY TnrDnn 4
( )
%/
k.
Effect of Groundwater on Plant Area Till Discussion of trRC Inseection Facts (frc: the Preliminary ffRC Report)
The increase in the plant area groundveter level allowed by elimination of the planned draina6e system was included in the design bases. Caces and Moore's consideration of.this design change is presented in their report dated March 15, 1969, which is included ~1n the Micland PSAR.
Evaluations by Bechtel involving the increased groundwater level are discussed in FSAR Subsection 2 5.k.10.3, and the supporting settlement calculations are available in the 3echte.'. Ann Arbor office.
Dr. Peck's discussion on the effects of enanges in moisture content en soll refers to his hypothesis that if sol .s beneath the diesel generator ,
building had been ce=pacted- too dry of opti=um (3 to 6f,), changes in moisture e.fter place =ent could ' cause ther, to settle signir!.cantly.
Soils placed within + $ of opt 1=um cola .ure, as specified, would not cause th!s effect. _
Conclu: icn The saturating of the fill, which was a design basis, was taken into I account in calculating settle:ents and bearing capacities.
\.
- Y . .
I i
I l
L
./
(\ 1 of 1 i l
t NRC PRELIMINARY TIfDINO 5 5 Compaction Recuirements for Plant Area Fill Discussion- of _ NRC Inscection Facts (from the Prell=inary NRC Report)
The density requirements for clay and sand as found in PSAR Amendment 3 end' Specification C-210 and es implemented are as shown below:
Clay Sand PSAR 10C% of maximum density 85% relative density using a compactive energy of .20,000 ft-lbs C-210 (after 95% of caximum density EC$ relative density Revision 5) using ASni 1557 Methed D (Zquivalent to above.)
As I=plecented 95% of maxi =um using sechtel Sc5 relative density modified test methed using 20,000 ft-lbs Conclusions
- a. Sechtel translated PSAR ':cepsetien requirement for clay in construction
-Q specificatien, however, failed to follow re quire:e nt . .
- b. 3echtel did not translate PSAR c0=;acticn require =ent for sand tc construction specificatien.
i l .
L 1 of 1
I
' i NRC PRELD(INARY FIMG 6
- 6. Moisture Control Requirements for Plant Area Fill l
i Discussion of ?a0 Inspection Facts (frem the Prell=1 nary !GC Report)
Specification 7220-C-210, Section 12.6.1, states in part: ;
i
" Insofar as practicable... materials f
{ ,
which. require moisture control,- shall l be moisture-conditioned in the borrow areas.... The water content during i compaction shall not be core'than 2 percentage points belov optisu moisture content ard shall not be more than 2 percentage points above optimum moisture content. . . .
...after the placement of loose =sterial on the embank =ent fill, the coisture con--
tent. shall be further adjusted as necessary
': lto bring'cuch :sterial within the coisture content . limits required for compaction."
On July 22, 1977 Dechtel ;A identified in.QAR SD ko that the field did not
[ take moisture centrol =easurements prior to and during place:ent of the i
'N backfill, but rather rel'ied en the =oisture results taken frc: the in-place
'(after ec=paction) soll density tests to control oisture.
As sitovn in Attachment 1, prior to Au6ust 1,1977, there vere no =oisture ceasure ents made at the bor:09 area or when the loose fill was placed prior to er during cc=; action. Moisture ceasure=ents were made after cc:paction, as vere density tests, and the results of both served as the acceptance criteria.
Fre: August 1,1977, to the cessation of fill operation with the enset of the vinter 1977-1978 season, there was a change. During this time, zoisture =easurements were =ade at the borr0v arec, but the ceasure ents were not ec= pared to laboratory standards. Again, no =oisture ceasure-r ments were =cde when the loose fill was placed prior to or during ec=-
! paction. Moisture ceasurements were made after cc paction and the data were used in ecnjuncti:n with the density tests, the results of which served.as the acceptance criteria. For this pericd, the data fr::
moisture censurements made af,er cc=paction, in conjunction with the correspending density tests, have been reviewed again and thirteen individual coisture = essure ents were found to be bekend ; 2% of op:1=um. l For'1978, toisture = essure =ents vere =ade either in the borreu eres or when the 10csc fill was placed ; prior to co=pactica, er both, but not 1
during ec=pacticn. These censurements were ec: pared to laboratory standsrds.
- Also during this peried, =oisture =easurements were nede after eccpaction and the data were used in conjunctica with the density tests, the results O of which- served as scoeptance criteria. Subsequently, 201sture =ea surements
%-);
i ll 1 of 2 L
6.- Moisture Control Requirements for Plant Area Fill (Cont'd)
( .
made after compaction vere revleued again for this period and the cases for which the post-compaction moisture data indicate measure =ents beyond 1,2% of optimum have been identified.
Moisture measure ents for the three periods are new considered not te have met the intent of the sp%cification regardin6 the locat10n and time of the measure =ents. Prior to commencing fill operations for the 1979 season, this requitecent will be redefined.
Conclusions
- s. < Final acceptance density criteria vere clearly specified end were
- 1mplemented from the inception of the project.-
- b. Moisture =easurements vere taken as a necessary part of the final density tests.-
- c. In-process colsture control criteria were not clearly specified and vere not consistently implemented. Clarifications and interpretations of the specification. vere cade without specification changes.
f~M .
U I
I 1
l l
s*%
l 2 of 2 l
t e ,, ,,-c, .--c,-,,. --,,,w..,,.,,... ,n , - -- ..-,n,a-,,- ,,v.u,rn......,,-w.,.~,,nn,,m...ww,wn,,- ,-as., ,-w,,.---,,.n.an,.,-,.,,,,,n,-,-,-,~
-8 e ~.
m .
. ATTAC19ENT l ,
i Moisture Measurements to Aid Compaction Control for Final Acceptance j Inose Pill ,
As Practical' Prior to Durisyt j
Time in the Comgiaction Compaction Period. Borrow Area (12f,) (12f,) Moisture Density i-
, Prior to Ho measurements No measure- Ho measure- Measurements Test taken j August 1, taken ments taken ments taken taken (mois- (density 19 7( ture controlled controlled here) here)
August 1, Measurements No me acare- No measure- 11easurements - Test taken
< 1977 to taken but not ments taken ments taken taken (density 1' uinter compared to controlled
- or 1977- laboratory here) 1978 standard
! 1978 Measurements were taken end controlled No measure- Measurements Tests taken l In at least one of these areas ments taken taken (density I controlled here) b i
t i
1
D A
/ NRC PPMCI&Urf FDDING 7
\ .
x.
7 Subgrade Protection of Plant Area Fill Discussion of URO Inspection Facts (from the Prell=inary NRC' Report)
For frost protection for foundations in natural soils _below the original grade, the . Dames and Moore report dated March 15,19o9, on Page 14 rec: -
- mends that if, " . . . foundation excavetion be left open during the vinter. . .
at least three and one-half feet of natural soil or sL=1lar cover re= sin in place...."'(e=phasis added). -
These instructions were transmitted in Sketch SK-C-271, " Winter Protection for Foundations," and approved and released by Project Engineering on Nove=ber 16, 1970, as an offielal design docu=ent.' This docu=ent was
.1=ple=ented T y Project Engineering direction contained in a =e=o to Construction dated November 16, 1970. The direction was impie=ented by the use of te=porary enclosures and/or strav cover for trea:e protecti:n oc provided by Bechtel'vher. construction was suspended in 1970.
For freeze protection for co=pacted soils, Da=es end Moore report dated March 15,1969, on Page l$ states, . . .If filling or backfilling opera-tiens are discontinued during periods of cold veather, it is re---- 'ad that all frocen soils be re=oved or reco=pacted pr10r to the rest =ptica l
of operati:ns." These reco==endations are included as follovs in ps Speci,ficatica 7220-C-210.
I ; ) .
-(/ 'a. Section 12 5.1 ,
- b. Section 12.10 delineating the require =ents.for vinter protection of e=bankment I
, c. Section 11 setting forth the require =ents for reconditioning, re=oving, l and reco=pacting the fills and ' excavations .that mere left open during the vinter periods of 1970 through 1973 To satisfy these require =ents, the top layer of soil was re=oved until the underlying layer was deter =ined to be acceptable by visual inspe: tion and/or in situ soil tests. The place =ent of =sterials was perfor=ed on the acceptable foundation soll after reconditioning-Conclusions
- a. Instructions to =eet PSAR require =ents regarding freeze prctection vere provided to Construction for natural soils via SK-C-271 and project =e=orandom, and for ec=pacted fill via Specificaticn 7220-C-210.
- b. '4here 'so11s vere not protected frc= frost action, specifications did
~
1 not require c =plete re= oval of the soils . l l
)
1 1 of 1 1
I
'\' A
\ /
s 4
i
\
O l
.I' t
! NRC PRELIMINARY FINDIM 8 Q,).% '
' - 8. . Nonconformance Reports Identified p.scussion of ::RC Inseection Facts (from the Prell=inary ifRC Report)
The nonconformances referenced by the. ITRC included 10 CPCo NCRs end 2 CPCo Audit Finding . Reports. Additionally,' Bechtei prepared 1 -indepen-dent NCR (NCR h21) and 3 other NCRs (NCRs 686, 698 end 1005) which dup 11-cated the essence of prior CPCo NCRs.
The 13 different NCRs are su= arized in Attachment l'with regard to the
. type of activity impacted by the nonconfor:ance, the Ir41neering dis-
. position, the uoe-es-is justification, whether or not the'probles was
~
. included in the 3echtel quality Trend Progrec and the type of nonconformance.
Durin6 the period from October 197L through October.1977, the ' repetitiveness
'of the activities impacted by the 13 NCRs was as follows:
- Moisture control 6 cases Compaction test .h cases
- Lift thickness. 1 case
- Soils-inspection 1 case Inspection plant.ing 1 case l Structural backfill Inspection 1 case l
. Gradation require =ent h cases.
Tes,t frequency . I case 1 (% j; ,
Total 19 cases (6 cultiple cases)
During the period frec October 1974 through October 1977, the repetitiveness of the types of nonconfer ances associated with.the 13 NCRs was as fellows:
Missed inspection 2. cases-
~ Failing coisture 2 cases Incorrect test data 4 cases Misinterpretation.of L specification 1 case Fa111r4 tests not identified 2 cases Othe r 2 cases Total 13 cases Attachment 2 provides a narrative of each NCR. It provides more explicit info:-cation as to the type of activity i=; acted by the NCR and the ty;e of nonconfor=anco, as well as. additional infer =stien from which to estimate the total number of individual nonconfo.~sness covered by each NCR or 1 of 2
8.- Nonconfor=ance Reports Identified (Cont'd)
(O 1 \s, subsequently determined as a result of further investigation required by the NCR disposition. Finally, Attach =ent 2_provides a description of the part and process corrective action taken in each case. ._
- Getting back to Attachment 1, 'it is shown that all but the first of the NCRs were included in the 3echtal Trend Progra=. In 1977 structural backfill operations were trended and resulted in '3 of the 13 NCRs i
(QF 147,172, and 17k) . The nonconformences were in the areas of testing methods, test criteria, and colsture content. Although the discrepancies had occurred earlier, it was not until review of the. turnover peckages that the nonconfor=ances were detected. Corrective actions taken included:
Additional surveillance of the testing laboratory by 3echtel QC Changes in U.S. Testing Laboratory Supervision (nev Chief and appoint =ent of Assistant Chief) l Training session on Specification 7220-C-211 on the centrol of l backfill sand Instructions to Procure =ent to ;-list the purchase order i A subsequent audit by Bechtel QA of the U.S. Testing's qA Progra found ,
it effectively controlled.
Attach =ent 1 also shows each NCR disposition and its justification. Of -
7w i the 13 Ncas, 9 vere dispositioned use-as-is. Each such disposition was
\,_- ~
- reviewed by 3echtel Freject Ingineering and professional jud6e=ents vere t
based on the following factors:
I-Degree of variation frc= established standards I= pact on quality and perfercance Location of tests.that failed Analysis with justifiestion of the variation Each use-as-is disposition was evaluated by Cp;o to encure that the -
dispositiening vas censistent with quality assurance pr06 s= IS1""~""~ 3 -
Conclusicas
- a. The identification of sc=e ncncenfer=ances verranting corrective action was =1ssed by 3echtel end vas unti=ely by C?Co.
- b. Except for NCR 199, the corrective action process was l=ple=ented.
- c. _Use-as-is dispositions vere =ade with justifications under. a disciplined process.
js k
v 2 of 2
_ . - ._ _ . . - _ _ - - . . . . . _ . _ . _ _ . . ~ . . . - . . - . - . _ . _ - . - .. _ . ~ _ _ . - . . . . _.
c I
\
> l l
)
i
=
. . !. 1 i
i -
I N
/r.
' -t a -
e ,
,; . i g . . , ,
r A- .g- -
e e . . .
- a. .
ia i
i i I !
z i
5 5
s.
E s
g .
<e g
s$e * .a y
g a f g .a S. e
- I a
aa e I 1 <- .
I I
- =, W
. E.
. w -
c 7.
s
=.
am z- C.
3
. w e
=
-d
= .ha e s w .. as we h a w $ 3 -* w w *
- 43 8 t.o I
w a
g
=
w
- 5 5 g a
= f g
e 5 e!
e e. E 4 e .n *2 A.
- e W 4 Y. .m 2 . 2 a a L s .
g a N .
w o .c . , , . . .
. n.
r e e
r a
g u= o a .z o . .
w
. . .p
- * * * .* *
- e
.n e e
a
. 5
- e e
!. n. u. .
- d
. :* 3s....!. .
2 s
1a 1 n
3.,1 - I. 5 4-% ".
j a a EF gh 3l}s.g; 3 .
. g 8 .s .,, ae
. :.. .. 4-
.i f6 e' O 73 o
E .I h.. b e.' 5i, m 2.
~I.I.s =4 oag $ . .E. d .. -
. .J a .
<wa.
<<d*
- u. w 3.
4
- g. :4 ; *=* . 3; 4 g, g e
,.,,, .s ryga -
6 33 < 2 .
- > * == -
g , ao se -
4.
- W .-5 Ed 3- g
- s. . a .d ;. : o;-g.g o. ed s= w4 -
- "R 2
..e-as
..e .-s *s.nn.7 e.
s2 =3
.a
.s .=
ey
- a. 2 .., >..
do a.
w a 4
e 5
w
, e ._ ., ;s<s.=- e ".
ea s2- -
.3 s
.s 4 ., * -<y o. .
4 .- _m
- . ._
- . a 2. 3 2
- 2
. .o
.. = m= = ag ". . a-
= e.
- v. a. . s
+
..... 5 ; =" sso ., s. ** .**
g-. -
e .e 3 o =s;*.}3 .==. .. .,
- a. .
.= :. a
,r * -
.o'
> <se
- . .. .... e.,
.g . e. <
- o. :s. Es a ss ,2
.3.:. e = = : as . =< :<
6 .o z uta<:
- tt =
a :w 12 3 a *
.o
<: " :: aa yn - : 5 2 o o o r=
s *= *h -4* r. = f.
.. . ~ -
\my 1 v = g , 3. :.1 = = ** * . 'a a a -e
."- w. w .2 . .s -=
z 4
... . * .g . *. <* .. a O
2 o . . . .
- co t
!! 2 c d
< a., ,
2 y , ,, ,, I . .
= .
unnun , !
ash I .J . .
u is ww:5 u.v: ; -
2 l
e -
f c mav , , ; I t wn:n .a , a
.e a s .-
t e)'
- s. un usaw wwo 'I . ,
g **Vm i
- i.
i o
@- mn: t i t;
<i u,1 -
i e
, s nui .
.emm:s . . t* . . .
V I
sanm is4Ma t
= i ; a: E n, !
=
E
- .- g s_ 5; 5 y ,
515
<oo* ! a 3 5 : :
a
! S 9 3 .S
.. <s
- 1. i. 1. : :
s .. 1. 1 E. E. ; ;
eg n
8 :
e
. a ,
, w
.. .. w w a a a
, s - #
.a. ,.
q ea (V'. - .,. ., s. e., .- . -
=.
=
x.:
- 8-us = -""
=
u 2 . ., w O e.
& .Q -0 0 00A -
, 3 Q Q a ea Q Q
- a. . . . - ..
.- , , # ~ ' ' * --psq.,. _ , " +'-** =***-s- -
- - , , , , . , ,_ " " ' ' * " A w y ,e . , , , , . _
f N -
i' % .
s '.. * .
/ .
l . .
y t- p ,
t
. ATTACIGG3rl .
q
.? -
4 PROCESS CORRECTIVE ACTIO*t PART CORRECTtVE ACTitut y
1 MR NO t(CR DESCRlrTI'Ota At3 SurrORTINC DETAll.5
~
A memorassJun f rem EEretton Jtrecting that a- Structural backt til e.aterial was delivered Bechtel tnCR 198 was tutttated. Tw.-a t y-a l u f)C be actified of all incontag st.tymente of !
.QF-29' adJitional s.ss.ples were taken from the s toc k-on 10 Jays in August and 5=pacat.cr 1914.
I l pile. Sechtet Protect ikgtneer tac
- s .it spost- structenrat backftll material was tesued on ,
j i only 11 days had tl.e material been inspected October 29. 1974.
i
' ar.J t uted. Of the 11, only one of the re- . tina was to use-as-te based on ti.c results
- ports was in the IJC file. ~o f conditional samples. - Taa of the. eleven i
J ~
repor ts were f o n.14 nJ placcJ ta the QC file.
I ICCR 324 written. the evaluated and accepted it.s. Testing and Bechtet gustity Centret-QF-31 Soll test itD-201 for plant area fill located lud eacht had traf alag seselone re-emphaeta--
14 feet east of 8.7 line med M feet mortia the in-g lace m.sterial with low seatsture con-tent based on a satisf actos y ccapacitun test . tag the acceptance criteria for sell teste.
ef A llac at elentluen 194.$ lud a moisture
~
I cou r ent 2. 9 I.cipw optia.um maistur e consent. result.
t *t - +
I i
A complete seview of,Bechtel Ho.llite.1 reactore 11.5. Teattar deutsed a ayates for checklag l f gr-68 The compact ion test 'El-142 taaen in the weet teste scatant a massar proctor liet and a and T ield work shea-ts used t y U.S. Tc=t tug was -
3 \ plant Jtko haJ 1.cen calculateJ ~ t. ming the - saater los book.
perforneJ by 11.5. Testing. Threo ad.ittinnel
.'. wrong m.aminum laboratory Jry Jrnetty for i
3 Bechtet it+ tit led rs ector r esult ing in a 961 s Jte.crepancies wese founit Jurtas this revitw. *
- 3 cong ac t iosa which is passtuc. Using the A total of 12 fiel.t tests were af f ected t.y the _ .;
4 .,
cur s et t state.um lahce. atomy Jry Jensity re- .ltscrepancies. Revised errosts were sut.mitted .
t
}
mults in $21 cuent action wittch ta f a t ting. for the 12 field tests. Falling test tun-142 -
I had been cleared t.y passing test itn-ILO. None .
9 of t he 12 field tests were fennJ falling after
- g , corsectl.=bs had been made. therefose. a Project d
, t 4
- Engistces ing evaluat teus v.is not neces sary.
1
. The waterial wav armave4 Jown to the required This problem was a result of taouf ficteat gr-120 1. Soll was placet i.etween manhole No 5 and monitorlag of the plectag crews and the
- f. above the sanitary newer in the west !!ft thtchnesses and compact cJ prior to cen-LinucJ wou lt . to al.tes as e a. work was Jane tot accordance to the Note on I plant Jake in an sincant. acte.t Ilft thick- lietat t. 6 ef. Drawina C-130 Rea 3 whicle le la f miens v.arying t.etween 9 and 14. tent.es.
l conf lict witt. Specit tcation C-210. A tratar
- l, l ' 2. In an asca not accessible to rulter j h_ m.cral. rore en an.1 us.orer rar- and nulpment. satt was plu ed t.etween man-
{ g hieHeaa.Jn.3ai eth.sni<-, ,,,,,,,,,c,,,,,, ,,,,,,, ,, , ,, ,,,,,,,
erwer in the west plant Jtke in uncom' C-l)0 Kev 3 cor rectrJ the coni t tet between pacted 111 thic6ac.,ses or 6 In nem. ,,,,,,,,,c_,3, ,,, 3 ,,,,3r,,,,,,,,,,,
i
[*;
- g C-210. This should ala.u be acted that tht. was in a un-q area.
t
- e-
~
,q .
. e 1.t . .
! t 9 8
, s.. - -
- ^
i i.
gh . .
4 .
g , 7 i .
L j ; . .
- t 8-i 4 .
g
. - . . . _ - . _ . _ _ _ _ _ _ - _ _ _ _ _ _ . - - _ - . , , +- . , , . . - - , - .-.
-m. .m_. ._ . ,t j _ _e m '~
N '
D s
~ .
, .g
. -[.
t I:CR Dt:.5CRIPTI0t AIO SUPPOJTit2C Dt3 Alt.5 l' ART COgRf CTIVC ACYto1 PgoCESS CORRECTIVE ACTION -
,j. ,
llCR NO . .
t cause of the reenconfoamance was steinter '
t' Quat tty Control ragtacers have s bserved the : Alt close.1 C-2tt!-4 ticlJ Instcettun rians were i QF-130 reviewed and similar situattuns as desciit.ed in .Te precliute 'pretation of spectitcattoes requirements. 'I matu la t placed in appromismately 12 Jach repetittoa. QCl C-1.02 will be 4t%t10 ents.trJ. Isethtrl QC Jessu weJ tt.=
!. unconpacts:J .1 tit e wheie s oller es sulpment was .
taseJ to inspect compacted bachit!! sad a not used to compact mates tat. ga rat. r t hana 4 t ue l. l i f t t h t cl ei.-ss u t s te nu t h ,
I Ft t.t Engineertug and Project I:nc t acer ing. It . training /Jiscussion mession was teld on.
- wa.s felt that since the lift thicksiess never 2l22/77. [
- a exceeded 12 inc.es and tt.at al.e in place Jenalty e
g tests at! meet t he 6t' 'C II t ni (**. pac t ion r equi re- .
men t s, whicle l a t hee r ea s. .e f or . lowering the lif t .
tht(kacus f rom 12 toutses to 4 inchem. Elia t the m.itert.al in-place is acceptakte.
I Shipacots of structu. Al haMill 'JelivercJ in Starting February 4.1977 tacontag struc- . [8 -
! QY-147 Structural backfill Jullvered on cecember 1 tural backitt! was controlled in occord-' [
1976, December 14 1976 and January 11. 1977 Octcher and howrm.her 1976 were reviewed fur 'ance witte the' Quality Control Receipt . .. ag (flepeat of elettar psotelem:t liCR*m 686 and 698 were was not teat =J for graJettom requirements or. Innpection Program. In aJJition. a trata-- I-
} QF-29)
Inspected.
wollten IJoittfying the lack of testing for- IlI*
l the dates ahowc aent ones notcJ ta t he rewteu ing messt.>n was he!J on rel.ruary 10. 1977 on the contral of Q-list - 1.ackf tll sand to 1 of October and taawenhee 1976. Project fugtneer- *'
j Ang .itst.oss a lmicJ t he n.ates tais use-as- t s, pacclude acpetition. In attendance weres ItCR t 93 was writtcia an.stust the following datest ICTeague,t.ead Clwil field fagineer 1 .
I tie s..her 26. Oc tober 29. tiuvember 12. of 1976; itChceL; 1.caJ QC Civil thatneer
' ' ' ~ ' - " '
7' l- .
J.enuar y 11. and Jam ar y 12. 1977. '.Frolert BlBollne. Ecclite! QC Ingineer Fuginee r lug's d i st.os t ilaus st .at ed. ." Test s c on-1Al*erklas. Superfetendent. Civit '
t Jikan. FielJ Engiacer. Civil [
J ct s.J ans samples pr ior to amt af ts r stie Jays utse.ed vera. found acceptable, in .ada t a lona, one Cary Coaster, tieIJ fngineer Civtl .
test w.s rue.J cted cu January 12. 1977 and Frtsh BCruhtch, and B.Arepton. Superinten-Jcut.
!- f ou.ul sat ist aeitus y. theref us e. Psoject 1ugtncer Ing co nuts with the FielJ 1ngineer recc.mmended the following approacle to control stie .,'
.I l s pos t t i ..a to use-as is". It shool.t he untcJ ntructieral backflit was discussed and *
, - thas the test aun Januasy 12. 197 7 use.1 tin- acaecJ upo.a by all paesent. the first '
l
. wrong steve staa n This Jata was t rum straphic trm k Jeliverlag backit t i sand each Jay ti.t c u po t a s t un. . taCR 6ttf. was rtatro agatust util not be allowe.t in it.e gate without I j sk c cel.c r I.1976 amt I cremhe 14 .9ff. for.yhtch release f rosa f ield receiving Jerarte. cat. - "
aptaranta te cly 495 tuna and $1 tous ac:.pecatwety The hn(htt!1 venJor has been instructed by-
'2 4
- were slettwercJ. I*r oj ec t l'.ngineer ing's J h. post- A*socurreena to have Lists first load'atoppedJ "-
j , ,.
tsun. it.e amples were taken on J yu N..we her. by U.S. Te. tang for test samples and Receiv- 8
- j. -
9 through hve=her 30. I ccrat er 3-13 .sisJ Decca- % -
h
- ber 30 were f ounJ acceptable. rar thermore. all M A hh1 cuite Mig j .
the n.iterials were ehtain.rJ fr.m same source, tai the sand stockpile area anel field i
- a. Thesefore. Ingineering concura vitti Fie1J' *I*I"E I * * ' * " * * * **N *
- i. Ear t acer tac's J e r.pos i t ion to use-as-tm. o
-f
[
3 W s w
F 4 .
. . e i .
j .
- d -
}
.. -r.
- . - , .-- ., .- - - . - , - ,_ ,. - c. _ ____ _
. * ;fm j m\, v.\ Y
\ f q
v
)
. J ~
l . - .
a PART CORRECTIVt ACTro;t PROCESS CORRECTIVE ACTIO:t '
! ! taCR ti0 NCR DESCitirT10te At:D surr0RTINC DI:TAII.S (Contd) (ContJ)
. qF-147 att subsequent loads are Jumped la a Jtf- .
Also. tJCR QF-147 statcJ th.at this esame problem I fercut holJ pile eacle day. QC wt!! be h.wl recurrcJ. It st a a r.1 in kcco cnJed Correc-tive Action 3. This s.ame pu ol.lc.a of se si ct s.ral notificJ in wettfag by U.S. Testtag of test l'
, h e kt tli mat f t.it lacking to.iJ.st le.a tests was ecsult s f or e. acto mile. QC will nottfy Field e
- Receiving if a ho!J pile to acceptable.
AJenttfled tan CPCo llCR e}F-29 tssu. J Octot.er 14 Fiel.1 Recc! wing will. tan aura, verbally 1974. 1he corrective action t o ra cc liute sat.t i f y supee v i s t one assJ tit.ysically semove the
! rep.titsuo fo- this 13CR w as .a au.as assJun f rom i
i* tl.e l'ro }cet SuperlateuJeat directing ttat tioLJ on tiae acceptable pile witti a release Quality Control f.e nottfle1 of all incoatag strned. S perwistoa will instruct the c rat t hmen wor king ist ti.e st oc ke t t s area met
- .t tpe.icnt s of r.t s ue t.se al har b f ll t m.it es tal w.as to move 8.nts' piles uutti stacy are marbeJ
-. '. t uur.l . Recently. Rechten QA tJenttiscJ tl.ta
^
setrascJ. IJhc a t he holJ p t ie s ar e m.ar n ed sa.se prob!run in QADR 5b-6 issuc4 eletot.er 21
,' 19 7 f.. 1he ent reet tve act ion to pseeli.Je sepsti- retc.ased. the c raf t savun w111 move them inte the m.6in stue.kpt se which is apptopriately-tion (or this QAhR was to une the following
. stasked. Field t'ngiacer ing will assure system:
enoutt i amaterial ta in the siata stockpile to g
- a. Each Jay,a Jelivery of stenstural b'.schf!!! sut. port constructina sretuisementa. t ai I is st ockpiled urpar ately. aJJit tua. tCta.htch of Receiving agreed to ~
1.. Da ti.c following alay the seaponsible Field give FielJ Enginecting written notificaBoa j .
E:ngineer ver tiles that the material was that a hold plie has been relcamcJ by QC
- trat cJ assJ t s accret at.le. tuctuJing the Jate of release and descrip-f
""
- I * **I* PII"*
- c. It the material vann*t tested, a test will t.e taken at this tii.e or af the material to j . .
acceptable. It will he placc4 1:n the a acceptable pile.
It ta ev t. tent that t he con n ective' act ion taken 3
f or tsCR QF-29 and QADR 5u4 ts not adeetua t e.
t)c t e r e.ine the aan.les~ lying cause/causes and
.1
+
propose fut al er cor s ect s ve act ton to pseclude a cret i t l awn.
ruolect I:ar.incettng st.ated. "A review of the No Frocess Correcttwe Action was determined
- 1. Test Report HD-359 taken itay 30. 1974 necessary because thte problem happened l QP-172 f a t te.t .tensit y test report etu-319 reveals that
)
for the northeast Jike station 29 + 00 i t.e su t i r etir esent ed 4.y (lit e t e st failed to stisce years hence. Also, these probleme 5 feet right centerline zone 2 at '
were in the dike section and we no longer 1 a
=ces the muisture content a s -tult ement s while had J!ke sections to be completed.
! elevat t.ni f.22 had motsture content nf meet lag al.e remisas t ion c r i t et t a**. I t is also 2.61 1.clow opt i .e mo t st ur e cont e-it.
I. 1 hts test had hecen mias krJ P f or pass noticed that t est to-h3 sut.st a ti.tes f or test ,
k-e l 1- .
1.
. .t . ._ . . . -.. ,
b
, ~
a we i .
e~.
~
=
j(
]L.
['-
d.
) - FART CORRt'CTIVE ACTION -
PROCESS CORRECTIVE ACTION ~ . }g ".
- licit 130'- NCR DESCRIPTIO:t At:D SUrt'OttTt?ic DtTAILS ..
(ContJ)-
QF-II2 (ContJ)
- 1. wl.en actually the test f a t '. ed .
ten- MI . Test PO407. m-2s6 and ten-308 takese * ~
1! ,
]; les Lt.e wictatty ad test W W around station 4 2. Tre.t Itepos t e f or the nor thee.t Jike 29 + 00 for Hu='nostheau Jtke 1.av met the.
to-M2 whte t was takens tt.ny 21.1974 at Jensit y and e.ot atus a 'contrat scetutsrevnts.
5-
$ ..atation'10 + 00 centerline zone 2 at ConstJettar.the test nesultz'in the net tt.bortag
- j elevation 622 4.aJ 94.52 coentuctiusa; d'***""'I"**"*'".ut ni t =.t.act ism a htewcJ.
j tus-M4 taken May 28. 1914 at stations e motsture cantent 2.82 1.cle w the net tman la
- j. 31 + 00 100 feet right of centerline tien of 2.0I f or test ettwh9 wa t t t awe tussg- '
.s .
, . -manJ Jrain zond ? et etewarton 622 had atitcant effect on the waterial placed. Stace -l cue. pac a ton an1 titt-M6 taken ttsy test m-m is lewatcJ away iso = tt.e Q-ttsted , -
}! '
I' 91 }
- 28. 1974'at actatici 29 + 00 100' feet right'ol centestine of masal Jr.ite zone ha M itt areas an.t no .atet y s elatcJ sa suctures will be locatcJ In thin an ea, e t.e test tuuM9 .
3 b 2 at elevat ion 622 t.md 92.2I co tut t ion. i.e acceptrat aos is. - Alm, st.e test s epos t 10-142 j
f~.! Test 62*- M t t.aJ heca marke.t r for pass was Inc ssu t and has tacen scolacJ En indicata wt.<n ac t u l t y L t.e test fallcJ. Test ** **"e" Pe " *a t c "- I
) ' '= "'" ec t '**"I'- -r J
to-MS a J M6 had t.cen aik,J r f or lua toit is .5 instead of %. h kr m and
'fati mud .secepte.1 by four roller passes. * 'I"' I"I I *" I"C "d * *N ~ I I *M ' -
- .l~.m.r sulter pasaca are not tt.e acceptance **"I M ' M "'" I'* dud i=st af the Jake senter- _ .4 '
l triteria in this area. 1inc. tt.ese a e-st a wIi1 he in the pla it itit area
- I, I
s.sf et y r e latcJ si s uc t re or apt e am wi l l f.e 3 g taa ;
i-[ lot a t . J ten t ail s .n s ea.
Theaetose. al.se four passe .
j (* of the roller can be accepted as .ute.6 e r . *.t .
ble Process Correcttwe Action wee Jetermined t
Contrary ta the requirement that zone i tus-It5'im 50 feet left na w.st.ot the dtka neccesary because thte problem happened a
!~ QF-lM cences tine at stati . 56 00. 5.ettian T.
three years hence. Ateo, these probleme
' taiperw tona t ilt a i.ould have not less th. net t>sawtug C-119 and Sec t t un K. l>s autng C-I t) are
?
202 pantor, tl.e 200 steve. tests 115 in tt.e were la the Jtke section and we ao' longer i !- tJentical ca al6e plant side (f.e.. west s t Je) _ had Jtke sectione to be completed.
nosth plant Jtke and tO-M9 and tabM8 in - 11.ca ciose, t est M -ll$ is shown- !
i .'l ehe os ti. cast Jike tud soit classific.et ton s f e t.c fitt.
j .
ze=ne 1 (letp-ll4) whicle t as S.2Z pa ss t.or. in a mne 2 atea h.ase.1 on elti.cr Seetton T.
- 8 m 810 2n st.e northeast. tin.retur. C-I t9 or sce s t..n tG tis.nwing C-It), . ;
th 200 mieve. Te s.t f ,! 3 a i s ans er.1 t ha t t he s c n s e J a sc s epane: t es in {
l- -
J tke t.aJ s.o t t cl.asm* f ita t inn z..n.: 1 (it.'tr-139) al.e solts test erposts. he s'e I n t h.: test loca- j
} wl.tch las 3,4% passtad 80* 200 :.leve. It asemi ani.t v.it types I t st rJ to the s e guir e s aret
- 8[ St.autJ t.e notcJ test 11% w ss t.*kret tiay 28 !
. , *
- tl J tits-M9 wer e takra tLay not always cauststent with the destr.it Jsawtus j I Jtke cross-settlaus (e.g.. z..n.- 2 es.s t er ia l 1914; test m+ .
. , ?,
30 1974 ma~ .t till-Blu was taken August 8 . .. ,
- j. 2, I l mt cJ .as e.a t ca t.a t a .e.t whes e z ne i esterial . [- ,
- .ho ild h. awe i.eca uscJ). th. wever, we tave' j
1974. E. 'I
.' n eviewed arports f or aJlacent tests in it e .
j; - I4 t
{
. a.anie victatty of test tilbMll . M9. and 440; *1 [
i
- I *
"} *
- . - 3]; f I4 .
a
- 1. *~
1 * .
e
{
e
- e
~
l .
, 4 i
, a *
(
f f .
9 1
~
I 4.
~
__x--____-.=- - - .
- - - - - = - - - - <, - .-
1 c.g 6.- ..
Y - [6'+\- .
I 2
j
< hl
- . u) r /
a-3~*'
' FROCESS CORRECTIVE ACTION ,,
-1 ART CORRECTIVC ACTION .
2:C1 1:0 - KCR DESCRIPTIO:t AED SUPPORTIEC DETAlt.S . .
(Coutd) '
QY-tF4 .
agata we conclule El.at t he m.me 2 ana t re t al la a ) ,
aly.
- rusic ! area a.l.o.alJ be ceaa alJen e.1 an an
- -i ut.t tet it is .u41Lely stat tiu: .dittes wool.t he- ,
accept.it.le ti s tu:re w *s e ca.nc lusive ev t.lcske
. ' ,. 4
]. ,
Lt it raunu 2 an.at crial h.aJ tecra widely uscJ in. " .
2_ . lieu at the sp.-c if icJ t meer w t.u.s ter t al . * *.a .
- , test reposts la tural do not support this * ,.c in-posittasa. Th.- a s pos t s f a us= adjacent
^
slie w1c Iai L y oO .'tu-l"45 IS9. aa J 4r4 Ja suet I
asupp.ne t a l.u theusca L t.at a zo e 2 s terlat is , .
at the locat ansas oss deses tlc 4 in tie test seport 3I 1herefaae. the t esguca.E for a Protect Tumineering . ,
evaluatl*a to "Jeteamine Elis' .si.reptahitity of .
fa j ,
st.e Jibe. .." lease-J u.s specut.at tawa alunut earcra in s.horJc.4 Jat.i Is aiot appsutislate, naas- Jos we , l lj bet te-we w.er rauted la s tils ca . Auy l'aoject .
I:uglacer tur rwaluat to.i would he lear.cd oa E tic --
sam.- t e:.t s eguert taif.as mat laus echtch alrea.*y B as i.e-en ag .,.t l acJ as auum.ilous t y C ma.i.=u r ut . t he camclusions would only he as g;oo.1 as the f acts '
A t tluiugh . ,
us.cJ as the tists of the evatu.itte.n. .
reconutztag th.at .hwumcatat t.us er rut s will
+
tuf re,pic t ly wrur, it is si.at s ecommended al.at -
- each Jucuecut J te.c rep.auc y t.e cwaluat ed as at.oogh
! it were I.nct. Our o!Itce is z.atisfied that ,
i .approg.a lat e .au. alit y cot.t s ul prugraus. tuctuJing ,.' .
v .
- . t'cotash suaveittance, shusla provlJe aJcgu. ate *
.f I co.af t.le nce les the Jike cuustruct ion an.t it s I l accept. ability. -
go.
) To rettesare our cartter evaluation, we recommen. -
} ,
acceptaace of test re . orts tub-159 anJ 440 based
~
a on the soit classifteation as a zone 2 mater'.at.
i ; .atheit in a location other ttaan as described 1:a
'; tl.a tent report. . . ..
}-
. I 5
a -
sl
.4 l 4 l l '. I .
?t.-
- i 4
.c y .
,.g ,
i
+
' . ~ ~
t .
r 4 . ..
L
-- _ . . -- -_ _ . . ~ . . , - _ - _ . . . . - _ .._...m.,_ ._.
k j'
s .
f^ .
N ,
i t
s\
liCR WO I:CR DESC;ttrTION AND Surr0lLTil:0 DETAILS j FA'tT CORRECTIVE ACTION Fr.0 CESS CORRECTIVE ACTICM -
QF-199 rart i Bechtel :tCR 1004 was written on the densit y I"'I I cou.rar y t o cliese requiremente. the following problems and b.chtcl NCR 1005 was wrlateu on t est s luJ tieca passed uslug incoe rect testing the moisture content problems. ItCR 1001 was A training seaston vae held on II-l&-II for
- s. c,t,,g p,,,,,,,g, y, ,,,y,,cgg,, ,ggg a
- Jata. - Uning El.e cor r ec t tasting data.,the disposittamaed use-am-ts; 1004 renatas open. .,,',g, t,,,,,,g ,,,,,,,, , gg,, ,g ,gg ,pp gge.
tests tall. ,
able proctors were Jewetoped to atJ the .
t:urtle l*lant talke inspet ter in obtainting cor rect values for
- g tus-790 (s. ample-J 7-16-74) shavs opt imum .lcsistty and motsture, it was felt that no .l 3
nutstuse rmitent l l . fe, it sidueld love been adJittais.it cuarective actt:4:s be taken in tle
! 9.5. Lislug stie con s ect optImue miotr.ture '
problem with Jensity tests t*p-142 and 21D-143 .
e' un i cie t of 9.51, i t.e ac t u.i t emo t a t ur e con t ent .
gn whict f.alling teste were si. asked pa%58 98. +
is 2. 2Z .ibuve opt imum moistur e cont ent.
~
since it occurveJ only in thy of 1974 and a
! fun-300 (sample.1 7-)l-7t) shows apt iemie tus esot been a recurring problem. Correc--
i moistuse content a s 21. 4. It e.hau'd have EI" **EI'in li.id Men taken at the M W - -
- t.ccu 1%.2. Yhts .stso sh<m.-s mi.ssB=ua tah Jry .
of July 1917 by 5cchtel QC and U.S. Testing 4
Jcussty as 1D1.2. It shoutJ have been 115.1. to mante adequatch clear f alling tesu. j tising t he t os s ec t optimum moistume runtent of *, T he r e f inr e, tlie correct he actica to Medude 1
It f Z. t he ac tual m ulsture camarnt is 5.41 '#P"EIII"" I"' ""I * *** "E
- E * * -
above opt issuna moistur e camtreet . Also using need siot be addressed.
- k . the torrect ma n t omsm. 1.ib els y Jenalt y of IILI. * '
. t he s. ors ec t percent of mania.nen Jens t a y is 86.J I. Part 2 j bi-377 (s impicJ 8-6-74) shows opt iansam moistur. *
- j. content as 18.0. It si.ould have been 15.2. Corrective nettoa had been taken as of the 4
Using the con n ect opt ie=am moisture content lact of July 19TT by Dechtel QC and U.S.
, of 1%.2%. t he ac tu.nl muist ure cosit en t is 4.5% -
Ter. ting to nore adequately clear falling i 3
mLove opts ===a moisture coutent.
tests. Therefore, the corrective ack ka to'
]
PrecluJe repetit.!on for not clearing fall- ..
f St ruct ural B.arkf ill
- I"A tenta need no*. be addressed. '
j tuut (./l (sas pled 10-14-71.) shawa sminlause dry - -
lih . tensity .ns 94.2. It e.hould have been 112.2. Using the corsect minteum Jay t al.
.lensity of 112.2. the cosecct pescent of
, selative Jenetty is 41.5.
9e t 2 -
) Alaio contrary to these resguirements, the 4
f ollowing test a haJ f a t!Ing resulta an.1 Jid *
- not indicate lieing cleinn ed by passtag tests j or tud been surked pe stag.
- . ' l.
t ..
4 j ,
q . . -.
j - -
1 .
- 6 1
m
N -['. {
~ '
-y 7 \
) .'
\ -
NCR EO I
. 2:CR ef SCRIPIlm: A:s SUPPORT 1t:C Di~ Tall.5 PART CORRECTIVE ACTIO'! PROCESS CORRECTIVE ACTION s .
I Qr-159 (Cues t J)
, e.
E91eh y a_ni_p p,e , ,;
stis-142 ;umpicJ 5-10-74) 61usus optleum ,
mot :s t u s e e o.it ent 8.0. meistess e content 10.3.
11.1s e est Iatled I.ut it la shown as passing. , ,
I tu)-14 ) (sa. pled 5-10-74) shous optimum a anoist ure content 11.8. moisture centent 11.4 11646 f.s t led I,ut it is shown as passing. ,
West P l .in t Dike ,
a ,
tus-227 (ma.plcJ 10-6-75) f ailed moisture .
[*
las t Isas anut l>cese C ledf ed. ,
- 1 Pl.nu t Asca l'Ill ,
tta t a t ui e_ . . k.
. a-Test rio' Date ..=rled Co.cactIon Actual of sm .
to 1311 5- 0-77 61.6% of Relative Dennity - ak' 1326 5- 10-77 19.5% 1 *..21
. .I 1328 5- 10-77 12.22 In .2% -
. f 10.41 13.21 !
1412 6- #7-77 . _ _
~
Stri.ctural nackttil
- s HDR 621 10- 4-76 78.0% of Relative Denialty gg 671 11- t2-76 74.8I of Relat twe Density l 672 11- ')-76 75.4I <>f Melative Density ,
- 685 11- '4-76 "36.21 of Relattwe Denalty .
I 636 11- '4-76 70.9% of Relative Denstry
,I 691 11- 4-76 62.0% of Relattwo Denalty , e 4
I
.I .
4 1;
.. ?
- $ g
. .1. , t f$
4-
- .a
.O g 8
S gp O e . ,
. ~ . ~
- 4 .
e
-6
--e - **
9
' " ~
- 7_- _. _ _ - _ . . _ _ _ . . _ _ _ _ _ _ _ _ _ _ -_ _ _ _ _ _ _ _ '1""-"- '-7'" - Y"" P'"--T*-+-- m P --d-"* 7 'e m _a_____________. _ _ _ _ _
%/
i pN- s p
v 1
~ .
(v .
1 j
- t
.t:CR XO ' ':sCR DESCRIPTION AND SUPPORTts:C DETAll.S PART CORRECTIVE ACTIOtt PROCESS CORRECTIVE ACTIOtt l
S.! . .
- Past A Part A&R Part A & B QF-203
' QCIR tio. R-1.00-15f,0 f or Zone 4A Fine Backfli g;gg.1094 was written to tJentify the soncon- The tenderlying cause of these coadtt tons *
[ was improper review of the test reports by references User *a Test Report No. 0610 and forming anterial 14 Fart A. Project Engineer-the acceptance criteria aaz ing d i spos i t t s.ned t h i s ma t er i a l "Use- A s- I s", th.ality Control. To psevent this eonJttien ,'
Ett 1055 was written ein Identify the nuncein- f rue recur ring, a t raining sesstem was held j
^
Steve Stre I rawing .
with canast rant ladtvlJa.als in attendance. t-100 I"'
- 8 "E '" L "f f'8 I I E E E* Field Engineering 1" _
ham d it.pos i t tuencJ t his e. ate rlal "Nejec t Far Q- l 3/4"90-100 thi s mat er t.nl v.is . nit y use:.* in Nosi-Q pn t g U e".
gfya p g. .jo
'
- areas. the underlytng cause of this conJit*on was 4 , .
3/n" - f,0 8 *2
- " "E ""** "" * " *
. #200 1-15 P.i r t C Jilferent gradattom regelgements on the 3'
Coatsery to the abova. Uses*e Test Report No.
r hased on respeusse given in Part A of letter QCIR and fatted to bring it to the atten-0610 seferences 7 5- 1810 % pasalag as the 0- lf 21 f rom J . .".ciegen to C. k ith t a dmuss. It van ti si of the Qc ttcceivtag Engineer. To accept.ince critetta i-ar the 1/2" eleve, con- ,,c c e ,,,, , , go, g.teld l'oglucer ing to J..stify the preclude repetit!oen. Else cognizant QC '
acqocut ly 941 pas .. J t he-1/2 sieve ad it enore stringent regula emnts nd it.e use of this enginects in both disciplines were restaded
- 8 was .nccepted when actually it fatted. material when it Jt.1 not =ces these requirements that close Interfacing te a necesstty.
r.ir t B Tl'e lu$ttlica?lon w.is given by Field l'aginect- .
Ing as f or sp.-e t f ylog a 12-20% range af QCIR tsa. R-1.00-2l05 for Zone 4A Fine agga eg.it e g.asslug then.al;h a #200 steve when j g Backt 111 ref erence-s U:.cr's Test Report No. spectilrattu.i C-210 gev 5 allows a rance of --== -.
. 10% anJ the acceptance critenta as 7-20 was strictly for commercial reasona. .The
- vendor said he lead a supply of 12-20Z mates tr.l.
Steve Stre Z Passing When this material actu.nlly tuencJ ==st to tre 111 .
. g- 3 6o~-
- I syn-goo it u.as still acceptakte lor se in acco Jance 3f4=
l gfy - 1 5 *80 witti sur spec t f Icat tuen. The only a:rror was in
] '
the disi.osittoestug NCR QF-201 by rewining the j 3 f g.a 60-85 y.gg Fmt ratlier (tous noting to use-as-ts.
gyog .
Cont n e y to the showe User's Test Report 380.
l'ai. Indicated 81% passing the'l/2** sieve '
s' and accepted, this sho.ild have indicated 911 passing the 1/2" steve and fatted.
2 .
rart c l * -
l
' g'- .
QClR the. R-1.00-in M fos-Zone 4A Fine {'
B.schl tti referes ccm User's Test peport Not* ,
', 08 % an,1 the accel.tance criteria mas .
i .
- {g. . *
.? e
, ,a9
-e ,
< t .
. . 4 m.
4 g.... Q 5
- ~. *
} . .
I .
s . e g ,
- = .
.t i . . ,
e
. . . - ,, - - - 4-
.g-g, g
-~g g g j
~
.. ~ . . V -
\
( ,
a*
l
. I *
. r PROCESS CORRECTIVE ACTION
? ART CORRECTIVE ACT10't
- ECR Eo ECa otsCaliTIct At$v surrent1!.c DETAll.S QF-203 (Contd) .
9' Steve Stre 2 Passing 1** I00 3
3/4" M- 100 M 40 I 1/2" 1/8" O-85. '
4200 12-20 I i
Contrary to tte showe. User's Test Report Ito.
- 08% had 111 passing the #200 steve.and it
. wa accepted.
Bechte! QC informed the Foreman directing.
Closed Out Bashfall was placed on a lift which was A reteer use taken in the area and the retest the solle work of the required notature I'indleg No 1 .tetesmineJ to lic greate- ttian 21 below passed (plant backfill test 1414)
- content 1tmits and what to do if a falling
! to Aud!L upt imus, aiu t stur e co-it e.it (plant backfll! .
- test occure.
n 22, act.ial 12.81). * !
l* !'eIn rt test tu t)$2 ot.tte F-71-21 uhen quest I.u.eJ, the Foreman directinr. the .
- mutts verk stated tasat he weuel.1 cania inne --
backi t tlinr. since sat t=Lic tor y come.ict ion ,
I haJ beca obt.itur.l.
,t acchtel qc suJe an evaluation concerning the Bechtel QC informed the Foreman directing Closed Out twitng the audit. t t was discovere.t that the Lt.e solls work of the correct test f requency 4
frequency of testing in the af fected area. It
{~ fl* Jing: Bio ?
to Au4tt F >s t.on J t u ret inr. t he r-e t t s w.'es k tic t iewed that a l.e s e twis ed f requency f or test ing of was determlacJ that between 5-13-77 and 6-17-77, requirements.
a f ield. Jensit y, and motstume content was 1 18.200 cubic yards of randum backf tll was placed l ilegert
. e as per 1000 cut.f c yards of f ill, soutli and cast of the Turhta= Building. Fifty-
- F '!7-21 seveN tests were taken en this autcrlat which rEsults in an overall test f requency of 120 cubt' ,
g yards per test. The maturity of this 18,200 cut.sc ya:Js was placed in a non-q area. .
9 I
8 a
s .
'.i
.4 y -
e, . , _
L., .
S m... ____ _ _ _ _ . _ _. _ - . . . - - - . _ _- . _ _ . . _ _ . _ _ _ , _ . _ _ _ _ _ . . . _ - _ . _ . ._._
J
, ..']_ .
, N]-
[
- 4- j.
O g
.(
V .
- ~#
KCR NO I;CR DESCRIPTION Al.11 StfFFORTINC DETA11.3 FART CORRECT 1VC ACTIO:l FA0 CESS CORRECTIVE ACTIO!( - .
Closed that ' 1he audit was perfosecJ osa sat t reports flerth The test results were recalculated and carrec-* liefer to IICR QF-199 for Findlag No 1.
FinJ1 a to 1 riant utko tus 72 (5-23-74) tt rount. Ps 514 tions maJc. The errore did not chanae the j to Audit' #9-21-74). L'est riant psta inn 2) (9-12-74) acceptance of thema teste even though they did
. IteI*M L thraur.li tB) 107 (9-27-7'). Staus e<<iti Isack f ill change ths test results.
.,. F-11-32 tuin 611 (10-1-76) thraur.h itna it28 O-38-77).
1 Pl. int Ave.: Fill ins 112 2 (10- 7-7 6) t'a** **ur.h .
j 988 1854 (tt-12-77) ma4 r.radittua reposts ( *T stuu.tusal I.a.Lillt o.stestal acceived l'chsuari
- s. . 1*>7 7 tair ourh August 31, 1977 tu assuse fall- .I j, ing teste have leern cleared by p.essing tenta; ei.al sa us e e untent s, u.a = Imue.
I
- correct opt t = u== ,
- unJ mtatoe um Jay tab densta tes have be.u useJ; . . . 6 j l the test r esu l t s uc r e pe oper l y ev.i tua t r4 f or I
- m ceptansr; .ind test n epos t s ca.ild lie located .
! la the Qu.ality Conteel llocument.itton V.ault. . ,
I .
- HadI J'E _1 . ;
tut Phnt pthe !- *
. .. i I, tus-2 76 .in.t 2 7 7 (sampicJ 9-15-76). 278 .
(sas. pled 9-Itr-76), and 285 (sample.1 9-17-76) . -'e E h.sve 134 in ts.e opt imon santatus e cenitent colunt .
. 7
+
Nort h Plant pike = ;;
' ~ ~
126-92 (GNd215-25-74) st us musminum Jry lab -
ll
+
Jensity 110.6 It should Isve been 101.4 . .
3 ttD-91 (sa.ep3 rJ 5-25-74) etious m.iminism stry lab -
., Jensity ll0.6. It should have been 101.4 ,
t- tu)-109 (s.impled 5-28-74) shows on.inimue dry lat *
, i
!* Jensity 10).4. It should have been 115.1 a
181-119 (s.nup t ed 5-28-74) st.uws inam tmuan Ja y 1sti, 4'
i p Jensity 127.2. It should h.sve been 128.0
- I :st-in (sampicJ 6-4-74) st.ows ot s tenum anoist ura- .t
. contcut.18.8. It shuulst have been 18.4.
1 .
"in-19% (6 nipled 6-24-74) slu us opt Imum mod s- .
I,:
tuve tuntent II.G. It should I. ave tecen 11.6. 3
- 3
..g
.~.
, i tun-2 21 (sacipicJ 6-2 5-74) stuous optinuam mals-i It st.uuld tusve been 11.6. - 8 .
J tun e contreet 10.3. * - -.'.
, . . g r
1 .
.I.1
- s. .
( * .j w -
j ;.c . . . ~~
e 6.e . *4 v
p,.
a y f
- s% .
, ~
,/ - .j '
I
. i. .
1-1 XCR NO tcCR DESCRIPTIO:t AIS SUPPORTIEC DETAll.S PART CORRECTIVE ACTIO'l PROCESS CORRECTIVE ACTIoll . .
- ^.. -
. (* FIndlag 1:a 1 ')(Contd) ,
I to Audit g etn-22 4 (nampled 6-23-74) shows opt imi.or mals-
- P"' tune content 13.5. It shu.sid have twc.s 13.0.
F-77-32 tip-217 (s.s ptrJ 7-11-74) ab=ws opt iemase sels+
4 j t ut e contenit 9.8. It st=>uld h,sve been 10.46 _
! This also shoue maximum dry lah density 126.8.
It sha.ilJ h.sve been 127.4.
lui-269 (o.ampleJ 7-12-74) shows mas tmum dry is'. .
~
density !!6.2. It should have been 116.3. .
g hn-290 (sas.ple.! 7-If-74) tious masts.um dry J ,
g lab Jensity 125.2. It sluwld have been 128.3., , ,
e
- g 11D-118 (sampicJ 7-19-74) shows opt im.m mula- 't y tun e contritt 13.0. It sho ld have been 13.3. .
1 t10-136 (saa.pleJ 7-20-74) slumas optimum moistus e l c a.n t en t 20.5. It abustd hae been 20.0.
1 '
l .
119-341 (s.imple.1 7-25-74) hluw-s opt im..a moistus a ll content 17.0. It +.huuld have berse 15.5. .
4 u 180-377 (s.impled 8-l -74) %uus m.imlau e lat> Jry Jensity 10*f. It should h.tve 1.cen 112.9. -
HIF 476 (same.ted 8-5 9-74) shrm opt ie=== malatua is * .
(untent 17.0. It st..mid h we lcen 17.1. ,
i i tin-512 (sampleJ 8-28-74) slumus maa ta..a lab dry ,
- I Jrustty 109.4. This sho.sid Isve been 109.0. . .
I
- 4 4 Stau.-tar.nl Richfill Arc.a a
MI K-419 (s.o pled 5-25-7 7) shows e inionen Jr y lata Jensity el 101.3. It should lave leccia 125. 3.
It .ilso si..us alal=um Jay lab elensit y as 90.3. ,
It abs.aIJ have beven 10'8.3.
1
- riant Area Fill i .
tg 21D-1762 (u mpic.! 4-8-77) (twem ma a l smas J r y sat. , * -
3 Jens'.ty of 117.0. It sba.lJ h. ave 1.cen tI7.f. ,
I. ttD-1300 (s.am. pled S-2-7 7) gins opt la a mula-
..3 Q ture content ol' 11.1. It al-ould have i.ce.t 10. '. . , ,
! y _,.
t =
- t -
- i. .
D i . .
i t . .
g , .
4
, -t
{
.-s, i . . . .
e t- _
ll _ . j'" .a . -
ai- . ,\ . ._
+ s -, 4 -
f, '
t . .
7:CR ho ~
l ' HCR RESCRlrTION AED Surr0RTtXC DETAlt.S . FART CORRECTIVE ACT101 .FROCE55 CORRECTIWC ACTIcet '.-
j Ft.6 ding sto 1 (ContJ)- .
! *
- A'"I I E
) hin-1385 (sampled 6-2-77) gives optimuss mots-
)' , ,
ture co.steent of 13.S. It should h.nwe been-13.4.
- ,f. .
t*p-I420 (s pled 6-8-77) gives opt imum mot s-suse content of 9.8 It should li.swe been 8.6. '~
j ~
I ~
lt also r.twes m.antemen dry lab Jesisity of 127.'
l It shinelJ teve b.-en 3 32. 9. .
} t 20-t$21 (s mple.1 6-11-77) r. t w es ma n t emen J a y 1.. h.-
- f. Jenstay of i17.0. It si.uulJ have be.en !!7.1.
- 8 fa 2 e folloutnr-Jtd not tu.llcat
. ad f a!!!ug res.ults asul og cleared by p.assinE Test reports Plan Area Fall te 1317-1320jllortli Flant D!ke m 4ta; and Structural Backftll let meter to DCR (IF-199 for Finetag to 2. .
tests.
g 620, 629, 432, 617. 67). 679. 700, 701, 757., " *
.767. 763 .ind 770 have been cleared by passtag
'l l'.7g 32 r l.au t Arc.s Fill
- i
' Ho let u. , :-) tests .ind Structural R.actif tll represented Test ?to. Date ample J - Cegac a l sut Actasal- Opy (ame"] l y tust 814, 861- and 862 was renowed.
- ttu 1851 10- 't-76 61.62 a *' a ve pensit y - ~
l 1855 10- 't-76 71. 5% - we tiensity reports Plant Area Fill ten 1853 !!55 2
1191 18- 4 76 76.62 i ve pensit y fTest 8ISI* 1894 1321. 13 3 7 l in8. 119 ).' 3198 1404 ~ ~
f .. 1t94 '!!- + 76 75.4%
- e tiensity 'I'I5* 1498.-1509 and St s uc t ural B.ic k f t il HinR j 1317 5- 29-77 18.01 . 1% 2% 25. 66). 664, 667.'680. 682. 688. 721 " '
I 1118 S-
- 77 11.5% ' IS 2Z 714 716-741, 744 746. 757. 168. 770. 785
- I * '
7M. M6. 84). 845, 889. 914, 922. M .
1339 5- ri-77 11.11 13.21 -
i 1320 5- i9-77 .. 17.21 - 13.12 938 S'8- 993 and 998 are.in a "teun-of*_
I 1121 3 i7-17 .94.0Z of nastuum Density anca muJ 1.4ve been given to K en Project
$ 1517 5- ,7-77 E'" 'R *"#" " "' 8 " I 8 3 " I"'s (Fleid) for.
12.4Z !*-.2% s i 1))$ f. - #7-77 9.8Z' 15.2% resolution in letter 1861'QA77. . .
i
- 1391 f. - s t- 17 11.1% 11.41. * '
I t',3 6 ail- 7 7 St.21 11.4% -
l j-
.l ' t r,t 4 f. !i s- 17 10.2Z 11.42 *
'1415 f, ->1-77 9.9% i1.4%
- f 1495 6- %-77 - 88.2% of Hastems Density '14.5% 10 sit -!
i , 1509 6- 6-77 II.*iZ - 15 2Z f :..e h riant pike .,
I i. m sta 8- 4-74 17.2f zo.02 i q
! E. -
~ I l P .
, y .
i .4 .
! 'i .
~
? . .
, g' S -
I g l -
~
. . i
, a g .
t
, 4 i -
. .. i
~
i
s f% 'fD h ._
I f, .-
s u .I. .
NCR NO NCR DEECRIPTIO'a Atra SUPPORTINC DETAILS l ART CC:tRECTIVE ACTION ' -
PROCESS Cone 1CTIVE ACTIott 1. -
l Fintting tro 2 - (Contd) - ~-
St ruc t us al Bac hil l t
~
l'-77-17 .
- - fla t et vie Test ;4o Date ampled' d'oe p.ic t, t ors ' Actual h th [ ." " '
h:nk 670 10- 11-76 77.3% of set.ittwe penstay ~ , ,
,.' . - - ~
675 10 17-76 S t . SZ e- Mc I4t i ve Ik-ami t y -
679 Its ?8s-76 79.21 of'hel.attwe Desistty 617 10- f0-76 73.5% of Relattwe Ilesistry f- ,
- 617 *l-76 76.1: of Eclattwe Deustry _
t6) El-68-76 51.0% ul De tas Iva th ust t y Is
'll-kt-76 ".
~
i 6ht - 77.1% of kelat ive Incuilt y .
I 667 ~11- i t - 7 f,' 67.%I eif Helat t wo ince.s t e y' ~
- 67) ll- 'l-76 )l.9E of Eclat twe ticusit y ,
l 679 15- ')-76 _ 71 t1% of Rel.it ive Inc.as t t y .
! 630 11- 'l-76 64.OZ ct Met.stive pcusity * - -d j ,
6HJ ll- *4-76 70.6% of MclatIve lkasity .
{ 6118 11- '4-76 77.lI of Relattre 1:.ussty - -'- *
- t 700 1- 15-77 7).01 of metat s c th uss a y -
Jul l- i l- 7 7 68.11 est Mel.at t we inces-e t t y , _
- 60. tf' **l Relat t we ficaus tly t -
778 l- l4-Il .
34.01' e.1 a. lat t we licusle y -=: L ou +g T i
734 3- ,7-77 --
-6 .
736 3- 5-77 7 9.t6% of Re l.it t wa steins t a y - - -
l 7 17 1- tt-77 41.9% of metattwe ticustry I 715 3- 8 77 77.41 cf Delati.e th-u s s e y -
759 3 6-77 70.t.1 of He-lat t ee i e.ist s y .
, 1 740 3- 'l-77 69.II of Nel.etive.bc sity 741 3- 't-77 7).ut of pe-tat ive pcustt y , , .
744 3- l-77 )6.7% of Met.attwe bcusity -
74fp 3- I 77 54. 91 et Del.at Ive lica:s t e y ,
i 737 )- 'l-77 65. 7% ut Relat ave th.u la y .
l g 767 3- 9-77 54.5% of Melas t ve pcusit y l 1h5 3- .ns- 7 7 66.9% at kel :goeskensey' ,
770 3- l0-77 6Ltat of stcl.ittwe pcusity d, 735 4-1 7-77 61. II of pelat t we th .i .t iy ,
f 199 4- J-17 75.8% of Relat t we th easi t y ,
876 4- 9-77 70.4% of telat twe thrusit y .
- 4 l '
- 84) 4- 8-77 66.6! uf Relat twe tiensit y 1.e 6 i-D- 845 4. 9-77 70.4Z of kelat ive th-u .I t y ,
- i 854 67.4I ut Net.sttwe D.sstty
- l. 5-1(1-77 ** .
4:,
4 s', * .
. 8.
t 1 '- . .
4
. 4: . _. . . _ - - . ,
e .
b
- .. - 4 .
3
- 5,
- i 8
1 . ..- ..
=
r-
,p .
y- yg p -
f
- .e w.----- - - - - . - - - , *- _.
~ , _ ' -
+
3..
_ _ {' m. -
j-
, ., 3 t 3 . . . . .
- \J r %f
.O g ,
g . ,
I . - ..
.- r
, - - , -; : e ,
i ** g 2 1. * -
L:__. m . _
,.f. - - -
l
$ 1 ., .
N s .
1 1 E j ,1 I:CR N0 t:CR. DI.SCRIPTION AND St'FFORTING DCTAll.S PART CO'tRECTIVE ACTION FROCESS CORRECTIVE ACTION -
3 Finding No 2 (Contd) '
i to Audit i ; Report 5tructural Backftli (Contd) i F-11-12 Maisture .
, I l T st Na Date -aq*!d -. Ca*tartson Actual Ops -haum l titut U61 3-Io-JJ ' 76.3% ni stelettwe Dens 1ty . ,
862 310-17 74.0% of stelat twe Deustty *
- 889 S-i3-17 65.5I of Relat twe Dens.ity 5 91 t. S.'4-77 9.0Z l t.BI .
l- 922 S. %J7 73.7% of Relative Density .
925 5. PJ-JJ 11.41 11.21 '
9 13 6- $6-11 56.5% of Relative Density j f l1 940 6 4-77 78.6% of Rel.itive pensity 63.2I of I:clattwe penstay -
i 1 4 991 6- T-77 s
l '993 f- 'i-77 77.4% of itelat twe pensity
. Costective Actton Regueste.t: Determine if ,
- ,- there es e pasasing te:,t s la the s:nme area to -
.,- l '
3 j ctrar these talling tests. .
k 8' .
! Relat ive l'ensit y Repos t s 19 and 61 were mies- Copies have been obtained and placed in the @
q Finding No 3 No Procar.s Corrective Action.
j t o Audit trag tron the (JC Vault. . Document Vault.
{g Report
,4 , F-77-32 i ,
Open Findings Re f e r * +. WCR EJF-l*J9. liefer to ItCit OF-1)9. Iterer to IIC!t QF-1)9
{ . ,
2 6 2 to i j
Audit Report l s .. F 12 To preclu te rei.et ttion to NCR QF-152 (the These findings have been identificJ on Bechtel 1he corrective nettons te preclude recurrence i opra !!nding same eleficiency as tielm). U.S. Testing NCR 1006. Dislent tloned 'tise-As-Is.** kan taken in the form of training for techtel 3 to Au.I t t Report JewetopeJ n si -u gritat ion form that has g td.ality Control personnel and training for 4
, F-JJ-12 (heck points alit include .to(san. un lac that ac tive ac t son still open. - Closca Imsed on
"' * **"I"A P# " ""'I*
the 70n r.' 3* *itental llett om aesy in lividual l 1 ( r..t.,,( op ,,it-se- As-!s., d i spos i t ion.
4
.( '
y.g g) 5 in h s teve h.as not l>cen <nce-c t -J. In
- 9 nJ.i t t lem. a t e .i t u las; se:.:.d on was he ld un .
g
~
l . Fehto..cy 21 1917. .
s a ..
! 4 .
h- ,
um. h I
T
~
? ,,
. . . m . .. m . - , s.
.c . .M Y -g *N..
, . . %, l. ; 1
.>; }-
5
_m, _
.# I '".
.s-e -
. ^ ~
+
. = -
s t
i%'
s .:
. . ~ - ~
. *
- m
,d *
. g
~ . . _ _ _ . _
15
- l F -
g
, - , s. ,
7
. t i
FART CORRECTIVE ACTICM I PROCESS CORREC*tVE ACTION -
-I "tiCR KO 1:CR DESCRIPTION A:O SUPPORT 1'tc DETA11.5 I
l I- Open Finding (Contd) l- 3 to Psoject Qantlty Control Instruction 144.
2 - AuJtt Report 5C-1.01 *N. ate r tal Test ing Se vices and
- g.,77_37 Concrets PavJoctices" Rev. ) Sect ion 2.7.2
' 6 ?
Reports. IIr4 A mantes. **Per f orm a J.stly
- scwicu of the out. cont s.ac t or
- e jobsite .
- inspection nt test t rg.or t s for acceptability.
completeness and the laboswtses y a hlet 's ~,. * .
{ .
signatuse for asacuete, stect, an.I sults.
, }, Sign mes.I .lat e on tlee aepert veriIyIag the
- 9 accesit ablit h t.a t um**.
Contrary to Elicse veeguirementst
- a
' ' Se p.c t as.nl ta it y ll t is.as. 5. imp _i d Ama.nc met.i tned ,.
.! p.g., ti..w.cr c- 270 1-11-77 #40 Steve -- 221.2g a l 4-27-77 fl0 5teve 217.lg
! 0164 0417 S-Il-77 #10 Steve - 221.4c * -
0411 3-16-77 #l0 Steve . 260.lg
- _ ..
0451 5-l3-77 #10 Steve - 211.7g . ~
8 (noi e f. 7 7 #200 S t eve - 2 2ft.0c j
- '0704 7-18-77 #10 Strwe - 249.5g .
I Corrective. Action Requesteit!
4 j
1 (1) Fa ceent these findings so Recht el ro uleci l'nglacertog emd obt. sin enntneestnr.
l l '
s at ionale f ree Bechtel rioject Inglacer- .
,!' 8 tug as to the accept.abilit y of ti.e , -
smiten tal these testa sepsesent.
e l- (2) tytJcut ly the cutt ert ive act ion ademn is' .
NtR-152 was neut .ide.gu.i t c . thereintste flee l*
- I s.ndn l y t g., c au c (s) a ..I t ake fuather cur s cr t t v - ac t B e.it t a ga s er 1.uta- ergsetitlon. "
.V .
e 4 6 .
- 4 O. .
J. =
- 4
- - - - ~ ~ - - _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _
9(,/ . '
NRC.PPILIMEIAR FDODU 9 l
settlement Calculations for plant Area Fin
.9 I
~ Discussion of URC Inspection Facts (from the Preliminary NRC Report) J
.Bechtel settlemant calculations for the diesel generator building vere based on designs involving a mat foundation having an applied soil pressure of 3,000 psf. The foundation. design was subsequently changed to spread footings .vith four independent generator pedestals having applied. soil pressures of k,000 and.1,750 pst, respectively (FSAR Subsection 3 8.L.1). Settle =ent calculations were not =ade for the final design conditions. ~'Recent ec=parisons show the settle ent estimated for the spread footing foundation condition was a caxicum -
of 8% . larger than that for the =st foundation. FSAR Figure 2 5 LS displays the calculated settle =ents, not the design basis. The design basis provided in FSAR Subsection 3.S.h.l.2 and 3 8 513 vas trans-lated ~ 1n deta11' design drawings and imple=ented -in the actual construction.*
The borsted water storege tanks are suppcrted ,in part by a ring type spread footing,' hut ecst of the locd is applied across the tar 2 bette=,
which is supported on fill (FSAR Figure 3 8-60) . Settle =ent calculations discussed in FSAR Subsection 2 5.k.10 3 for the berated water storage tarks, censerystively used a unifor: equivalent circular :st founda'.ica A \ "having an applied soll pressure of 2,500 psf (FSAR Figure 2.5.L7) . The ,
ring type spread footing pressure is 2,500 psf and the tank-applied
, 1 l '( (,/ pressure within the ring. foundation is 2,000 pst. Because the actual
[ pressure is 2,000 psf over mest of the foundation area,-this settlement estimate is consertative.
' Settlement calculations assu=ed a ecmpressibility parameter of 0.001 vhereas FSAR Table 2 5-lo gives a ce=pressibility para =eter of 0.003 In this calculation the difference in paraceters would result in a =2ximus
' increased settlement of O'.3 inch.for the diesel generator building. Fcr ,
the berated veter stcrage taris the difference vould be lesa. Differences in estimated settlements resulting frem foundation and soil ccnditi:ns
. cited are s=all and within the accuracy limits of the analyses.
- It has been discovered that se=e =anual holders had not received pages 523 These pages vill 'ce and 52b vhien centain FSAR Subsection 3 8.h.1.2.
trans=1tted to all manual holders.
Lj 1 of 2 t
I ,.
+ - , - - - - . .4.a.,. ..., -
, . ,, -,e--., - . . - , . . _ . , . , . . ~ . . , _ , - , , , . , m . ,, -~. . -
( 9 Settle =ent Calculations for Plant Area Fin (Cont'd)
\
- Conclusions
- a. Tne diesel generator building spread footing foundation, vhich ,
constitutes the design basis, was translated into the detail design.
However, a design change to the foundation was not recognized to . I affect a previous settlement calculation, but this did not signifi-cantly affect settlement estimates.
I
- b. The assumptions used for the borated tank settle =ent calculations l are appropriate for the type of design utill:ed,
- c. The wrong ecepressibility factor was used for settle =ent calculaticas, l but it had a minor i= pact on the resultant values, l A
4 i
e e
4 e
e l
l l
2 of 2 l
1 ... . . . . , , = . - . - . . . , _ , _ _ , , . - , . . . _ , . . . , , . . . . _ , . . . .. . _ , _ . . . _ , , _ , _ , . . . _ , _ , _ _ . . . , . . . . . _ . _ _ . . . . . _ . . . _ _ , . - _ _ . _ _ , . . . . _ . _ .
-c - - .-. .
.(-
j+,
t
- ( NRC PP metARY FEIDIT,10
. xm _/
~
- 10. Settle =ent of Ad=inistration Su11 din 6 Footings Discussion of NEC Inspection Facts (from the Prell=1 nary NRC Report)
The investigation of failure under the admini:tration building was initiated in September 1977. The results of the investigation in the l tallure area are s" -*..rized below:
Type of Investigation' Results Unconfined compression test Very soft to medium (11 samples) stiff clays Two borin6s One boring showed soft to cedium stiff clay
. directly under the footin6 and stiff to hard clay at lower elevations. The other boring was satisfactory.
Five tests on percent Percent :cepaction below co=paction. Proctor curve acceptable li its for four run on sample representing tests
(N these tests L ' t. '-
The results of the investigation initiatec in September 1977* in areer
.outside the failure area are'su= arized below:
. Area Type of Investigation Results Power block Observations and construc- No evidence of structures tion survey data settle =ent Strip - Load tests Sattle:ents within footings in acceptable ranges administration
' bu11 ding east -
of failure area i
j Sixty feet Soll boring Soils l
south of acceptable -
E diesel very stiff
. generator to hard building l
l Footing fer Soil berin6 S0118
.the evapero- acceptable -
tor buliding very stiff to hard LI 1 of 2
10.= Settlement of Administration Building Footings (Cont'd)
/'s
', Based on the above investigations, th'e administration building grade bes=
)- failure vas concluded to be a local soll failure. A =eeting was held in
'w/.
Septe=ber 1977'between the ' Chief Soil Lab Representative, Bechtel Lead Civil Field Engineer, and Lead Civil QC Engineer to discuss the require-ments of the proper proctor celection for fill pis.ce=ent tests. U .S .
Testing was notified by letter of the require =ent to select the proper proctor.
CPCo site personnel acknowledged awareness of the ad=inistration building soil failure on August 25, 1977 The CPCo Project Manager learned of the ad=inistration building grade beam probles shortly af;er its occurrence (August 1977) . The CPCo Project Engineer did not recall hearing of the administration building grade bea= proble= prior to diesel generator build-ing settlement discussions. This was not unusual because the field
~
nor: ally would resolve their evn problems and request assistance only when necessary.
Conclusions
- a. 3echtel investigated the nature of the failure and, on the basis of the infor:stion available at the tL' determined that the failure was localized.
- b. Because nor,e vere thought to be necessary at the tl=e, there were no program changes lapie ented to preclude the possibility of repeated erroneous selection of the laboratory co=paction standards. However, f,-_,Y Bechtel advised U.S. Testing as to the need to i= prove the selection
\u,/
I of ,sta ndard s .
l l
l l
.(~'m\
\ /
2 of 2 I
l l ,
l I
l- . - - -- - - ,_ - _. , __
-r l
1 I
/3 NRC PRF.LIlGIARY FI?QIIG 11 h'
11'. Interface Betveen Diesel Generator Building and Electrical Duct Banks Discussion of tfRC Inspection Facts '(fro: the Preliminary ifRC Report)
Four vertical electrical duct banks restricted settle =ent of the diesel generator building. This condition was caused by two ite=s. First, the '
ducts banks passing.through the building footings were stepped (enlarged cross-sectional' area) below the openings provided in the footing. In some cases the mud =at filled the ares between the fcoting and the larger duct bar.X, 'thereby providing support for the building at that location.
Second, the duct banks passed through the backfill layer and veri bedded in a stiff natural soll layer below.
A 1-inch separation gap vas provided between the duct bank and the diesel generator building footings to allev for differential settle =ent between the duct bank and building foundatien. The' detail was shcun in Drcvings C-1001 and C-1002. - It was net anticipated in the design that the duct bank would be constructed larger below the footing than at the point of penetration of the footing.
i i
The design require =ents of the duct banks where they penettste the tcundation and =ake the vertical turn are shcun in Ilectrical Drawing .,
E-502. These details were = edified to facilitate construction without
/'~'g recognition of the 'i=;act on the civil design require =ents previding j clearance for free =ove=ent of the building foundation. Moreover, the *
\- - =ud=at filled the space between the larger section and the focting.
Drawings and specifications per=1t the use of Zone 2 randc= fill naterial in plant area fill. Structural backfill was placed in local excavatiens in accordance with Specification 7220-C-211. Leen concrete was used to replace structural backfill in confined areas as per=1tted by Specifica-tien 7220-C-211, Section 5 13 which states, "In absence of structural backfill =aterials described above. . .leen concrete, as specified in Specification 7220-C-230 =sy be used ." Use of leen cencrete in re- '
stricted areas is a nor=al constructien' prac-ice and was controlled by the field engineer's approval after inspection of subgrade. Correspon-dence (3E3C-o63 dated Dece=ber 27,197L) addresses the use of lean concrete as an acceptable replace =ent for Zone 1 and' 2 =aterials only in areas of the dike disturbed due to trenches or te=porary excavations.
Conslusions
- a. - The diesel generator building settle =ent was restricted by the enlarst -
ment of the electrical duct banks or by the specified allovable use of lean cencrete to replace structural backfill in confined areas. Con-crete backfill wa s not used indiscr1=inately.
- b. There vas a lack of design interface between the electrical and civil drawings in that the electrical draulc6 did not recognice the effect of the enlarge =ent of the duct banks u;c the civil drawing design vhleb atte=pted to provide free relative =ove=ent.
. ['~'\ .
( .
1 of 1
+.c' ,I,---+ .,e , -w- .~c 5--, a e ay%-,,-t_n i ----,-,,,m., ,e, , - - . p_ , . - . - + - ,,.-,-w
e n s 3RC PRELD G A.'{t FINDI C 12
\ s_-) : -
12.. Soils Placement and Inspection Activities Discussion of URC Inspection Facts (from the Preliminary NRC Report)
The Bechtel Geotechnical Group has provided tecnnical support for soils placement on the -Midland Project. Placement'of soils by Canonie repre-sents the major portion of soils placed on the jobsite. For q-listed verk, inspection has.been performed by a Canonie quality Control In61neer with soils en6 neerin6 1 placement experience in excess of 10 years.
Additional overview cf Canonie's work has been provided by 2echtel
. Civil Field En61neers and quality Control Engineers.
For the 3echtel scope of work, soils have been placed under the direction of Civil' Field Engineering personnel. . These ir.dividuals are either Graduate Civil Engineers or persons with related on-the-job training.
l
' The Civil Field Engineers discussed verk plans, problems and sclutlens with craft personnel and vitnessed sensitive operations as the verk ;
situation required, although they were not physically present at all !
' places and times while.verk vas being-perfor:ed. They were en call at all times as the situatien required.
Bechtel-Civil quality Centrol Engineers (qCIs) have inspected, witnessed, or surveilled 3echtel place =ent of Q-listed soils. These qCIs were
- certified in accordance with ANSI NL5 2.6 and trained in the requirements !
I i of QC inspection plans .
I k QCIs vere in soils, placement areas as evidenced by quality documentation includin6 Inspection,. Ncnconformance, and Discrepancy Reports. The following tabulation provides approx 1= ate numbers of each type cf report ;
prepared by' QCIs. '
Field Soll.
1 Inspection
' Plans and Act ive Inspec- Noncon- Discrep- i Record' Time tien for:ance ency De signstien Period Report s Recorts Re pe rt s C-210 8/73-11/76 65 8 MA i C-all 8/7L-10/76 21 3 RA C-1.02 10/76-Present 109 8 31 S/C-1.10 6/77-Present 13 - -
S/C-1.05 7/76-Present 93' 2 -
Total 301 21 31 i
The require =ents for field densities and moisture centent are found in Specification -7220-C-2C8, Table 9-1, "One per every 500 cubic yards of fill."' The test must be taken within the frequency enveicpe, but there i is no additional require:ent as to the accuracy of the test location.
In the event of a test failure, noncenfor=ing =sterial was revery.ed .
t O
i
\
l of 2 o \
- 12. Soils Placement and Inspection Activities (Cont'd)
One case was reported in which moisture was added to clay in a non-Q area vithout reworking. Review indicetes this was an isolated case.
When moisture was added to the soil for purpose of compaction, the soil vas reconditioned in accordance with Specification 7220-C-210.
Conclus!cns a, There is insufficient data from which to draw a conclusion as to whether or not qualified personnel vere directing the fill piece-ment activity.
- b. The measurecents associated with the density tests were =ade by qualified U.S. Testing personnel,
- c. Soils engineers were not 'on site full-time after 197h to verify place =ent and ec=paction as indicated in specification C-501. l
\ .
t 2 of 2
-_ - . _ , . _ _ . - - - . - , , . , . . . - _ _ . , , - _ . . . - _ . . _ , . _ . _ . . . . . . . , . - . . _ . _ _ . . . _ . , , . . . _ . . . . _ . - . , _ . _ . _ , . _ - _ . ~ . _ . -
l e l l
1
\ I
.t l' NRC PRELIMINARY FEDUC 13
- M/ .
13 Inspection Procedures For Plent Fill Discussion of NRC Inspection Facts. (frcm the Preliminary NRC Reports)
During the summer 1976 the Bechtel QC Program underwent. a for=at change from Field Inspection Plans (FIPs) te quality Centrol Instructions (qCIs)-
and Inspection Records (irs) . At that time an analysis of FIPs C-210 and C-211 and QCI C-1.021rdicated that no adverse trends were apparent in a the' soils.vork. This indicated that e change was' justified to a survell-lance mode from the initial inspect and vitness cede which had been used from the beginning of ecnstruction'. The codes are defined in Section 3 3 3 of T220 SF/ PSP 6.1, as follows:
Inspect (I) - Visual examination.or ceasurement to verify the confomance of an~ item or construction work operation to predeter=ined quality require =ents.
Witness (W) - To watch over, observe or visually exacine a specific.vork operation, exa: Inst 10n or test which is perfo med by others.
Surveillance . (S) - To progressively =enitor by randerly.
witnessing and inspection, items and verk operatiens
'O ' before, during 'cr after in-process construction. This Q- . inspectign 'setivity requires that the QCI physically-verify. the work operations described in the quality Control Instructions to assure they are perfo=ed in accordance with inspection criteria require:ents.
These . verifications :shall be peric=ed as often- and for as long a ti=e period as..is necessary to effectively a
monitor the designated Activity / Task.
- The design docu=ent charceteristics subject to RC, whether by the I, W, or S mode, re=ained the sace for all plans. ' They included:
- a. Material free of organics
- b. Material =oisture conditioned
- c. Material not frozen
- d. . Material ec=pacted to density l- e. Lift thickness required ,
j' f. Work area clear of trash, debris, and unsuitable caterial -
j g. Backfill =sterial not placed upon frocen surfaces
- h. Backfill esterial confomance to drawing requirements
, Inspections, witnesses .and surveillences required by these plans vere perfor=ed as evidenced by inspection, nonconfor:ance, and discrepancy T reports.
l
\
~
1 of 2 l
I
13 Inspection Procedures For Plant Fill (Cont'd)
Conclusiens a.. Neither the characteristics subject to inspection or vitnessing nor the type of inspection or vitnessin6 vere changed; the degree of inspection or vitnessin6 was reduced by going to a surveillance
'(sampling) plan.
- b. The decision to change to sa:pling inspection is questionable, in
, retrospect, reccgnicin6 that the bulk of the prior successful experience related to Canonie's activity and that a change vus being made to have the activity perferred by 3echte1.
- c. The sa:pling (surveillance) plan was inadequate in that it did not s specify conditions or criteria under which there vould be increesed sa:plin6 or a return to 10C% inspection.
t a
l e
\ 2 cf 1 l
l
~
NRC FINAL CoffCLUSI0 TIS L
14.. Discussion of the NRC Final Conclusions '(from the preliminary NRC ?.eport)
It is ~ou.r position that final conclusions of a general nature e.re inappropriate because their all enec= passing natu.re renders them i
subject to interpretation beyond that which is supported by the inspection l facts. Specific conclusions are appropriate ar.d we have included our i specific conclusions in the preceding pages.
i t
f l
)
\ i
\
3 I
i i
- l. .1 of 1 !
n j
./ s
( 1-I I
-y = y g ( mwwY er774 ****N't 9-W"'?-9 'F M7 F'r& *P F f DY W'S N W W W 7'f f - ** -*
,r ATTACHMENT 6 f*
f
( ) . .
- g r:ucLEt,R REGULATORY COVJ/.It:"lON r/AmWGT03, o. C. 20sGG l
[%2]j
' - ~~~ m u un . l e
i 6
Ocekct f os: 50-329 l
'0-330 . l l! :
l Mr. S. H. Howll ;
Vico President '
, Consur.:rs Per.r r Cc.w.ny 212 L' cst I;fchig:n Avcnue Jcckson,1:1chigcn 49201 ocer nr. no.:ci1:
SUCJECT: 10 CFR 50.54 REQUEST REG /RDIl!G PLANT FILL .
At the U.ctings on Fcbruary 23, 1979, and March 5,1979 at the ARC Rcgion III Office in Glcn Ellyn, Illinois, the circumstances associated with -
I sLttit:.;:nt of the diesel generator building at the Midland fccility.cre discussed. This discussion v:as part of the investigation being conducted by Region III. Rcprescntatives of the staff ft om headquarters cttended the ec:: ting on Mcrch 5,1979. The staff stated that its conccrn is not liraited to the narrow scopo of the setticra:nt of the diesel canerator building but exttnds to the various buildings, utilities and other structures located in and on the plant area fill. In addition, the staf f expressed concern with ycur quality assurance program.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as eranded, and Section 50.54(f) of 10 CFR Part 50, additional infomation is requested regarding the adequacy of the fill and your quality assurance program for the Midland site in order for the Comnission to detemine
- whether cnforcecnt action such as license in:)dification, suspension or re-vocation should be taken. Accordingly, please subnit complete cnd adequate responses to the.cnclosed requests within thirty days after roccipt of this letter. Your responses should be sub:nitted by cover letter signed under octh or affirmation. In those cases in which a cceplete response cust cwait the results .of future activities, an interim reply should bo given within thirty days addressing the cdequccy of that cetivity to provide the ksis for a suitable reply, cnd the as';ociated schtdulcs for that cetivity crd rcply.
A
[ \
L.J
)dif W
^
Mo4lbol3Y
7 r
l l
-(
d .
\
I Mr. 'S. H. Howell IMR 21 G79 i
. Csasue. ors Pct:Or Coc.?any l
Should you destro clarifications or other discussions of the enclosed rcquests, picase contcet our Division of Projcct Mcnagonent, Sincerely, l.
' $ w Harold R Ocnton, Of rcctor Office of !!ucicar Recctor Regulation
Enclosure:
Reauct,ts for Acditional
- nforc:. tion ec: Sco next pct:
t .
e 6 9 &
E l
1 l
e a
. . . . , ...,,,,_,,.--,..-ne.v.--.r,.~w,r ,_~. ,,w,,.r. ,,,,, ._., - #,,_..-.,,v_,,,,.,,,,,.,__,..-, . . . . , ~ . . . , . , . , , . . , . . . , - . . . , - - , , . . . .
l e
Consur.:rs Po.tcr Company g.M 2 1 1979 cC5!
Hichael I. Miller, Esq.
Isham, Lin:oln a Boale Suite 4200 One First Hettor.cl Plaza ,
Chicago, Illinois 60670 Judd L. Bccon, Esq.
Consur,:rs Po'.tcr Company 212 Ucst Michtt:n Avenue .
Jcckcca, Gichiccn 49201 -
Mr. Pcui A. Pctry Secretc ry Consur.nrs Pc.fer Company 212 W. Michigan Avcnue Jackson, Michigen 49201 Myron H. Cherry, Esq.
Ono 101 Plaza Chiccco, Illinois 60511 l
( Mcry Sinclair -
i 5711 Sunwarset Drive ,
l Midicnd, Michi'in <8640 .
Frcnk J. XcIlcy, Esq.
Attorney General i Stcto of Michiscn Enyfienn.:ntal Protection Division 720 Law Guilding Lansing, Michigcn 48913 Hr. Vcndell Marshall Route 10 Midland, Michigan 40640 1
Grant J. Merritt, Esq.
Thompson, Nicisen, X,layerker.p & James 4444 IDS Center SO South Eighth Street Kinnacpolis, Minnesota 55402 l
+ .
k v/
% , a A, to w.M,,_,*= . _.
m , ------e,-- r on, -ee - , gn- .,_.v,, ,-,,-en, e-n ,-- --
,.,ay y -- e- ,-n-
t q
ENCLOSURE Requchts for Additional Information.
Rcoarding Plant Backfill Settlemont_
- 1. Ycur quality cssurance (QA) program, which falls under the provisions of 10 CFR 50, Appcndix B, was appliccble to the technical inforr.: tion thct rent into the PSAR cnd FSAR and the design cnd construction of the diccel g.ncrator building. In our view, the unu:ual settle:n:nt prob 1cre, at the site points to an apparent lack of ir.plerentation of certcin QA progrcm rcquirccants. Thcrofore, provide the folloiting:
P (a) Identify those quality assurcnce deficiencies that con'.rf buted t.o this probiern, the possibilitics of these deficiencics aing of a generic ncture end affecting other arcas of the facility, and describe the corrective actions you have taken to prcclud2 these deficicncios from hippcning in the future; (b) L' hat assure.nce exists that the apparent areas of centrcdictions
,m in the PSAR and FSAR as described by ICE during the t..;ctings of .
- February 23, and Merch 5,1979, do not exist in othcr ccctions j C}
(
of the PSM and FSAR dcaling with rn:tters other thcn fill? -
(c) Investigate other cctivitics not associated with the fill, but 1::-
portant to safety for other systerns, cc:,,ponents, cnd structurcs of
- the Midland facility, to detennino if quality assurance deficicncies er.ist in view of the apparent breakdann of certain quality assurance controls; identify those itetus investigated and the rcsults of your investigction; (d) Considoring the results of your investigation in item (c) ebove, describe your position as to the overall effectiveness of your QA program for the design and construction of the Hidicnd plant.
- 2. Discuss the consideration given to, and estirrate the cost of grouting cny nctural lacustrine deposits (scnds) upon ditch safety raiated structures cro founded.
3 '.' During the incoting on March. 5,1979, you stated that on August 21,1978, construction survey data indicated a setticmont cpprotching the raxirum value given in FSAR Figure 2.5-48. Horeover, your response to staff request 362.12 by FSAR Revision 18 states, "In July 1978', the settlcrant of the diesel generator building exceeded the anticipated values sheen
' in r$AR Figure 2.5-48." Clarify this appcront inconsistency.
/^\ 1 f
Q D
e
- - - - , . . - ~, *.,,c- , ,,., .- ~ . , - - , . -
e - ,
t -
- 4. Specify and justify the acceptance criteria which you trill use to judge the 4cceptcbility of the fill, structures and utilities upon conclusion of the prc1Ccd progrem. Compare these criteria with thct to dich tha
> , tctorial ecs to have been compacted by the original rcquirc .:nts ser .
forth in the PS/Jt. The response should consider all arcas where prelo:d.
ing is cithcr planned or in progress (i.e., diesel generator building, t
, borated r:ater storage tanks, diesel fuel oil storage tanks, Unit 1 trat.
fortar, condentate storaga tanks, and othcrs still under cycluation),
Ocscribe ho's conformnce to these criteria will ecsult in cssurance that
- unccccptcblo residual scttle 2nts ccn not reasoncbly be cr.pocted to c: cur
- over the lifo of the plcnt. For ccch such area, state the cxtent of ecsidual sctticznt t:hich will be pcrmitted and the basis for each limit.
- 5. To s; hot extent will cdditional borings and m:csurements be taken after completion of prolocding programs to ascertain that the material has been corpccted to the original requircrecnts set forth in the PSAR7
- 6. You propose to fill the borated water storaga tcnks and measure the ecsulting ctructuro sctticm:nts.
i (a) On dict bcsis do you conclude a surchargo no greater than the tank loading t:ill achieve compaction to the extent intended by the
[] critcria stated in the PSAR7 !! hat cssurcnce is provided by the I
(V f technique that residual settlem:nt for the life of* the plant will
, 4 not be cxcessivc?
1 ' (b) A similcr procedure is proposed for other tanks, including the I diesel fuel oil storage tanks, cnd should also be cddrcssed.
1
( -
(c) The borcted water storage tanks hcve not yet bctn constructcd and I
are to be located upon questionable plant fill of Yarying quality.
Provide justification why these safety related tanks should be cen-structed prior to assuring the foundation material For is suitable example, for supporting those tcnks for the life of the plant.
can the tanks be removed with rocsont.ble effort without significant f r. pact ?
- 7. Describe in detail how you will deter nine the adequacy of the electrical duct banks in view of the previous loading caused by contact of the diesel
' generator building foundation with these banks. Describe correctiYe m csures which may be takt.n in the cycnt of unacccptcbic results.
' 8; l' hat tolcrcnce is laced upon the alignment of the diesel goncrators end upon what is this imit based? Ho. will the present differential scttle-
- ntnt of the diesel generator pcdcstals be corrected? Discuss the extcnt l
g -
l A
j I
, e- , ~ --n. r.,- , m--+ --,-.,,w --v,.. -e ,
l l
f '. . ,
3 and rate of residual settlement of the diesel generator pedostals
! predicted over the life of the plant. In view of the variebility of l
the foundation rt.cterial indicated by Bechtel's Interim Report 4 to MCAR 24 which was forvarded by your letter of February 23, 1979, how can long term diffe,rential settlen. ant be predicted with sufficicnt l confidence to assure reliable startup and oporation of the dicsc1 C:ncretors Phon necded7 t! hat surycillanco program (cad inspection frcquency) for the podestats do you intend to conduct to cesure dctcetion of misalignment before these limits can be reached? Phat corrcctive cction, and the basis therefor, do you propose if these itcits chould be approcched?
- 9. Based on the information provided in your Interim Report HumScr 4, it cppears that the tests parformsd on the exploratory borings indicate soil properties that do not moet the original compaction critoria set forth in the PCAR cnd spt:cification for soils stort. Provide assurance t'.at the soil under other Class I structures not accessible to exploratory
[]-
O boring cuots the control compaction rquircmants.
- 10. Yeu have stated that tha fill is settling under its own ucisht. l.'ha t i / tssurance is provided that the fill has not and will ^9t settle locally under stnsctures with rigid mat foundations, such as portions of the cuxiliary building or cervice unter pump structure?
- 11. In vicu of the variations ' Indicated by presc.nt borings, what essurtnce exists that vcrtical borings taken adjccent to structures are sufficicntly rcprcscntttive of fill conditions under the strue tura?
- 12. Do:urent the condition of soils under all safety related strvetures cnd utilities founded on plant area fill or natural lacustrino deposits.
Besed on the results of investigations, compare the proporties and p;r-t l formence of existing foundation materials under all expected loading con-ditions with those thich would have been attained using the criteria stated in tho PSAR. If the foundation materials are fcund to be dcficient, c
l discuss tr.acsures that will be taken to upgrade them to criteria stated in l
I the PSAR.
O l
tO
,V
-~ -n,- y--..-. ,-r- ,,w , , <-v n, ,rere ,- ---ne , ,e, .- w ,.., ,,
.l l
~
- 13. Ho.1 has the lack of compaction and the increase in coil copressibility I
aff6cted coil-structure interaction during soismic locding cod th:mfore the sciscic rc:ponse spcctra used in design?
- 14. For all scismic Category I structures (including, but not licited to '
I the dicsci g:ncrator building) which are located on fill, proYide the results of an evaluation showing which structure you predict cay experience settlemants in excess of that originally intended, and
. provide an ovaluation of the abilit'y of these structurcs to withstcnd the in:recccd diffcrcntial scttlement. For the dicsul concrctor building i cr.d/or cay soisnic Category I structure diich exhibits crteking, cyclucte l the effects of the existing and/or anticipcted cracks on the perfom:nce l of tho intcnded function of those buildings. 'lhe calculcted stresses
' for scismic Cctegory I structures at critical locations should be tcbulatcd cnd cc.ipared to that of cllo.:t.blo stressos as stcted in the cppropricte ACI Codos.
- 15. For cil scisti.ic Cctcsory I structurcs which cre partially lo:ctcd on fill cnd pcrticily loccted on glacial till or original soils, provide
- a dctc11cd cycluation of the cbility of thcsc structurcs to withstcnd tha l
l
(~}
L difftrcntici sc.tticmnt. The possibility of not having a contcct surfcce betucan tho str: eturcs and the fill, due to sctticxnt occuring prior to
[]/ or during a sci:;mic event, should be considcred over the life of the plant.
-\ .
U 16. Since the picnt crea fill .is apparently settling under its own neight dict cssurcnce exists that the fill has not- and util not settle 1ccc1Iy I under piping in the f,111, resulting in lack of continuous support cnd
! ccusing additional stress not accounted for in design?
- 17. Id:ntify and docurrent the current condition of all scismic Cctescry I .
piping founded in the plant area fill. Include all piping founded in the plant croa fill th( e failure could cdverscly impact safety related structures, foundations cnd/or cquipernt, Also, discuss how Code -
allowable conditions will be assured t'iroughout plant life. If any ossential piping has now or should latcr approach Code - alicuable
- stress critcria, or ccnnot be'dctcrmincd, that m:asurcs will you take to allcvicto thcso conditions?
- 18. For .cistic Category I piping and all piping whose failure could cds .. iy impact safety-related struc'.urcs and/or systems, whether l buried or not, dosc. ribe what evaluations you plan to conduct to assure that such piping can withstcnd the increased differential sotticent botucen buildings, u'ithin the sam building, or within the piping l cystem itself without exceeding Coda - alloc:cble stress critcria.
The potentici influence due to differential sciscic cnchor rovce.:nt
.should also be considered. Discuss that plcns you havo to esstro ccc$1cnce eith Code - allo.:tblo stress criteria throut: lout the life l of the plcnt. .
I O( /
v 1
, I
- 19. The piping in fill under and in the vicinity of the diesei scn:rator building could have deformations induced either prior to or during
- the prcled Progrcm. L' hat is the present status of any defc:vation in tha r444 and that ultfrute deformations are predicted. If tny -
dcforu:tions cro or ef t1 be excessive, what actions are being or will be tcken to correct the condition?
! 20. Provido assurance that the stress icycls of all components (e.g., put.ps, vcives, vesscols, supports) tssocicted with sciscic Cctccory I piping cystc 4 thct have bccn or uill be c::poccd to increased ccttic.t:nt will tia nithin their code-allouzble stress 11mits. Also provido cssurcnce thet deformations of activo pumps cnd valycs insta1 Icd in cuch systcr_s will b3 tapt within limits for which consentnt opcrcbility has been cettblished.
- 21. Ycur letter of Occedce 21, 1978, en the settic: rant of the diesel g:ncrctor foundctions and building cdvised us that the use of a proloed to densify the existing fill material in place had bccn selected as the major cor-rective cction plan. Gechtel's Interim Report 3 to MCAR 24 forwarded
.by year lctter of Jcnucry 5,1979, identifics six alternativo plcns for corrcctivo cction, from a.$f ch your soil consultcnts have advised that only tuo suitcble options exist at that tim (i.e., the proload option or
(
(q tho option to remove and copiace the building and fill retorial). We requ're the following cdditional ,information regarding the basis for l t celection of thcso tuo options:
l (a) Pmvido a cost coaparison of the tuo options. Includo, by major iteus, en estir.ete of the cost of replacing cach safety rotated l
structure and utility (e.g., piping, ccbles, etc.) locctcd on or in the qucctioncble plant arca fill. .
In the cycnt the protocd option should fail to provide ceceptcble results, what cdditional costs will have cccurred tthich would not 3
otherwise hcve resulted had the removal and replacem:nt option been solc<:ted originally? Upon uhat items would these cdditional costs have bccn expendcd7 .
' t' hat savings will have occurred if the proload option provides acceptable results, compared to selection of the rc=ovat and re-placenant option? In what creas will these savings have occurred?
(b)' Provide a detailed co6parison of the impact on construction co .pletion batween the two options. L' hat schedule penalty is cssociated with cn I
l unccccptcble recult for the option sclected?
! ~
f
'[
v i
i ,
i
" m pr g er e y 7 gr - - - - * - - v w *+
- , .- n, _,...x.. ., . - . . . ,
.o .
=
\
e .
(c) Discust for occh option the probability of cchieving tia ccrce of co:stetion intended by the original require 2nts ctated in the
, PSAR.
I (d) Phat other significant fccum influenced your solcction?
E2. 11.c follo. ing infort: tion is required using the e,ssuotton thct work i in to ctop on cil cetivitics related to construction of structurcs '. 9 cyctens cnd utilities affcetod by fill (rthether such .cffcct is cither presently knotin or suspect), including any rncchanical, clectrical or civil cetivity involving a significent cxpenditure of funds:
(a) id:ntify cny schedulo frc. pacts on construction completion detes as a function of n.3nths of def y over a period of 24 c::nths.
(b) id:ntify cny capital costs of the dolcy cod qucntify them.
(')
c Idcntify cny other cost or schedf e fr.ptcts ccsociatcd with a halt or suspension of construction for a period of 3 r.?nths, 6 7[)) unths. 9 onths.,12 runths,18 conths, cnd 24 c.caths.
V (d) Id:ntify the principal construct!cn cctivitics thich are to take plac,o over the nout 24 r.:enths, with strticular rcfcet.nce to those a r.r.tvi tirA/.v.nc.te.t.r d t:1th stMictIsrcs, systens, co.%.)oncnt. ..and.
utilitics cffected by fill sottict. ant, uhtthcr such scttlen:nt is cithcr I:no'itn or cu pect.
(c) For those activitics idcntificd in respense to itc:a (d) cbove, identify each which is significant in tems of ucicht cdditin to structurcs founded totally or pcrtly on or in fill.
(f) Identify all altcenativo solutions associated with the plcnt crea fill settlement which uoald be foreclosed by continuction of en/ of the cbovo cctivitics.
i
=
a v
1
dTTACHMENT7 Y ,
f - ** o- .
f\ .I / \ (
s.
y!9 21 '977 r.
, r. V af Docket No. 9' Docket U . 50-
~
- ~ Consumers Power Company ATT*t : tir. Stephen H. Howell Vice President 1945 !Iest Parnall Road Jackson, MI 49201
'Ge-tiemen:
This refers to the' investigation conducted by Messrs. G. A. Phillip, E..G. cellagher 9.nd G.,F. Maxwell of this office on December 11-13, 13-20,'1978, and January 4-5, 9-11 and 22-25, 1979, of activities at the Midland Nucicar Plant, Units 1 and 2, authori:ed by h*RC Construc-tien Permits No. C?PR-31 and yo. C?PR-82. The investigation related to the settlement of the diesel generator building at Midland and the adequacy of the plant area fill. The preliminary respits of this
.(
s investigatbn were discussed with Consumers Power Company and Bechtel Corporation representacives in our office on Feb*uary 23 and March 5, 1979. The report on the matters discussed during those meetings were included with cy letter to you dated " arch 15, 1979. " hat letter also set torch the principal matters of our concern .se a result of this intestigation.
i Enclosed is a copy of the report of this investigation. In accordance
~
with Section 2.790 of the NRC's " Rules of Practice,'.' Psrt 2, Title 10, Code of Federal. Regulations, a cop'y of this letter and the enclosed investigation report will be placed in the NRC's Public Occument Roon, l
except as follows. If this report contains information that you or l
your contractors believe to be proprietar'; , you must apply in writing
- to this office within twenty days of your receipt of this notice, to i
withhold such infor=ation from public disc 1,sure. 4 The application
=ust include a full statecent of the reasons for which the infornation is considered proptietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
j %
l (V - oasics > I i. i e i
3,,,,,,,_
- - i ; i i i
i, i,
e a e > i........__... .
-e r - e s ,.i,.a, ,
ta,voru.w an ,,,,p.,,3....,... 3.....,,.
%se e , nsais-- .a
4 i +
4 A y[.
(,
'( .
f.
'('
P'8 22. 15 9
- 1 i Consumers Fover Cocpany 4 L
~I The'results of this investigation continue to be under review by the J NRC staff. Upon completion of this review you will be advised of any enforcement action to be taken.by the Commission.
l f-
.!. Should you.hava any questions concerning this investigation, we would i be pleased'to discuss them with you.
e
.g Sincerely, I.
James C.-Keppler t."
~!
i ,
Director t
Enclosure:
IE Investigation Reporta :*o. 50-329/78-20
- t and 24. 50-330/78-20 t
4,
-): ,
cc w/ enc 1:
1
- Central Files
' Reproduction Unit.NRC 20b
[ ,
' ' d POR Local PDR I NSIC-
"! ' TIC I a Ronald Callen,.Pichigan Fublic
' Service Commission
, i Dr. Wayne E. North Myron M. Cherry, Chicago
- ;t,
\
i
- o. .
f
.- -( mt t uup.... i nu. I Rut o,,,c,,! ..u..n..y. , I n..u........,....yl y.. F; Tioreili
'f s J D mus ysappler
.a a j I. .sva m c>.??.h..iI. 11P.i n l Manell /9 .s..................................................
... .. ...... .............. . 4.. ... .....
!. f- s 4 7 t> I_ .,1./.1. 9./.~. 9. . . . . .. .I . . .G.a l. l.a. b. . . rS,.i ,l ,_. S.f h . D......l...................l....o...
k.i.G M....
. : 9,- :a w = m 7. . t. .: , .,m,#,,...,...,.,;,,,.,,,.;,
i G'~;
. - - ..c . . - . ..
f fv ,
3 (- (
U.S . NUCI. EAR REGULATORY COFO!ISSION OFFICE OF INSPECTION AND LS70 RCD!ENT .
j REGION III Report No.. 050-329/78-20; 050-330/78-20
Subject:
Con'sumers Power Company 'i Midland Nuclear Power Plant, Units 1 and.2 Midl.and, Michigan as Settlement of the Diesel Generator Building a
-(
i Period of' Investigation: December 11-13, 18-20, 1973 and January 4-5, 9-11, 22-25, February 23, March 5, 1979 Investigators:
,,. hV&#YW4 G. A..Phillip
- w f ,/f,7 7
[I J 3-)3-79 E.; . Callag er.
.g
,0llt:"~'
G. F. Maxwell 7_/9.7y Keviewed 3y:
f dayes, D.N! g Ch f 3//p[y?
. Engi"aering Support Section 1 /
FiuAelli,?
il n[ief 8f//!
/
Reactor Construction and .
E:rgineering Support Branch f,& T iv Olu N!/'7!"I7 C. E!'Norelius Assistant to the ~)irector I-i.
I l 7905o20lV2
e
)
)
f} . (' ( i K_/
REASON FOR INVESTICATION l on September 7, 1978, the licensee notified Region III, by telephone, that the settlement of the Diesel Generator Building and foundations ;
experienced constituted a matter reportable under the requirements of 10 CFR 50.55(e). Written interim reports were subsecuently submitted by the licensee by letters dated September 29 and November 7, 1978.
An . investigation was initiated to obtain information concerning the circumstances of this occurrence tc determine whether: a breakdown in the Ouality Assurance program had occurred; the occurrence had been properly reported; and, whether :he FSAR statements were consisten: with the design and construction of the plant.
t SCOPE This investigation was performed to obtain information relating to design and construction activi:ies a.'f ecting the Diesel Generator Building foundations and ;he ac:ivities involved in tha idantifica- ;
tion and reporting of unusual set:lement of the building. The f investigation consisted of an axamination of pertinent records and '
procedures.and incerviews with personnel at the Midland site, the l ./ ,_s} Consumers Power Company offices in Jackson, Michigan, and the 3echtel i f\ x- / Power Corporation of fices in Ann Arbor, >dchigan. ;
/
l .
l l
SlYMARY OF FACTS t By letter dated September 29,1973, :he licensee submitted a report as required by 10 CFR 50.55(e) concerning an unusal degree of set:1e-ment of the Diesel Generator 3uilding (DG3). This report confirmed l
'information provided during earlier telephone convers'a:icns on or i
about August 22, 1973, with the NRC Resident Inspector and on September 7, 1973, with the Region III office. This report was an interim report and was followed by periodic interim reports providing additional information l
2 concerning actions being taken to resolve the problem. Further testing and monicering programs and an evaluation of the resultins data have been undertaken by the licensee :o determine the cause of :he settlement i
and the adequacy of the corrective action being taken. Ihe results of these efforts will be submitted in a final report :o the SEC.
Information obtained during :his invas:igation indicates: (l) A lack of control and supervision of plant fill activities c:ntributed o the inadequate :ompacticn of fcundation material (2) correc:ive actict i
regarding conconformances rela:ed to plant fill was insufficien: or l
l pm
/ T t t-QJ w_s l I
r' L_,\)~'
( '
inadequate as evidenced by the repeated deviations from specification
- squirerents; (3) certain design bases and construction specifications relat.$1 to fcundation typa, material properties and compaction require-ments vtre not followt't; (4) there was a lack of clear direction and support between the contractors engineering office and construction s.ite as well as within the contractors engineering office; and, (5) the FSAR contains inconsistent, incorrect and unsupported statements w1:h respect to foundation type, soil properties and settlement values.
,e % e q( t
- . de* Y e
e h
/
O \
\ h
( (
v DETAILS Persons Contacted During this investigation approximately 50 individuals were contacted.
Twelve CPCo personnel which included corporate engineering and quality assurance personnel as well as site management, quality assurance and quality control personnel. Thirty-two Bechtel personnel were contacted.
These largely consisted of site engineering.. quality assurance, quali:y n,s., . control, survey and labor supervisors and personnel in proj ect engineering, quality assurance and Geotech at the Ann Arbor, Michigan office. Three individuals amployed by U.S. Testing Company were also in:erviewed.
Introduction On August 22, 1978, the licensee informed :he NRC Resident Inspector at the Midland site.that unusual settlement of the Diesel Generator Building (DG3) had been detected through the established Foundation Data Survey Program. Uhtle the licensee regarded the matter as serious it was not considered to be reportable under the provisions of 10 CFR 50.55(e) until further data was obtained.
,s Following the acquisition of additional data from further surveys and
[ \ a core boring program which was initiated on August 25, 1978, :he
\ _,/ licensee concluded the mat:er was reportable and so telephonically notified Region III on September 7, 1978. The notification was followed up by a series of interim repor:s the first of which was submit:ed :o Region III by letter dated September 29, 1978. Subse-quent interim reports were transmitted by letters dated November 7, 1978 and canuary 5, 1979.
An inspection was conducted by Region III during the period October 24-27, 1978, to review the data then available; to observe the current condition af the structure; and, to review current activities. Informa: ion regarding the inspection is contained in TRC Inspection Repor: No. 50-329/78-12; 30-330/78-12.
On December 3-4, 1978, a meeting with SRR and Region II! represen:2:ives was held 4: th .9 dland site :o review the status of :he problem, to l discuss oper i:*2s identified in the aforemencioned inspection report and possible corr:ctive actions.
( Identification and Reoortin2 of Diesel Generator Euildine Set:lement Sur eys to es:ablish a baseline eleva: ion for the DC3 were completed by seentel on May 9, 1978. As a resul: of :hese surveys, :he Chief of Survey ?arties noted what he considered :o be unusual se:clemer.:. He i A l t i i /
l %d !
l l
l l
R 7 '
(
,f-
{t [
< '\
-indicated that.from his experience ha would have expected about 1/3" sectie-ment. The July 22. data showed a'differencial settlement between various locations' ranging from 1/4" cosa maximum of 1 3/8". He promptly instructed his survey (personnel to resurvey to determine whether the data was accurate.
- The' resurvey confirmed the accuracy of the survey data. The Chief of Survey-
. Parties reported the survey results to the Bechtel lead civil field engineer.
1 The lead civil field engineer said that in July 1978 the sectiement of a pedestal in e.he DGB was noted from surveys and about a week later a 1" discrepancy was noted when scribes on the DG3 were being moved
~'
up. He said that ati that time he was uncertain as to whether. actual sectiement had occurred, the survey was in error or the apparent discrepancy was a construction error. .He instructed the Chief of Survey
' Parties.to check his' survey results and to perform surveys more
' frequently than' the 60-day intervals. required by the survey program as a means of determining whether actual settlement had occurred and
- whether settlement continued.
The Fda'd Proj ect Engineer was also informed of the apparent settlement
- s. and. concurred with the-lead civi'. field engineer's actions. He said-Se had toured che. building at that time and he saw no visible indications
'of' stress-which could be expected when unusual settlement occurs.
'The. lead, civil' field engineer said the DGB was monitored for about a lJ fN ' month. He compared the amount of settlement being experienced with the-(
. settlement values reflected in Figure 2.5-48 of the FSAR and did act
. consider it reportable until those. values were exceeded. When the secclement did exceed those values as indicated by survey data obtained l- . on about August 18, 1973, he prepared a nonconformance report with .
the assistance of.QC personnel.
Tae July 22 survey data was transmitted by the site to the 3echtel Project Engineering of fice -in Ann Arbor by a routine transc-tttal memo
~
dated July 26, 1978. The data was received at Ann Arbor, processed through document centrol on August 9, 1973, and was routinely routed to the Civil Engineering Group Supervisor. He stated he did not review the data but placed a route slip on it indicating those members of his
. group who should review it. .
The engineer in the Civil Group, who had-established the survey program l' and who'was responsible for' assuring it was being carried out, stated i
he reviewed the data and did not regard it as unusual. For that reason he.did.not bring the matter to anyone's attention but merely reuted it cc ,other personnel in the civil group. The engineer responsible for l-the DG3'said he did not see the data before the settlement problem was r identified by the field in a ncnconformance report.
y _
3_
s ,_ ~ __ _ _ _ .. - ,_ . _- .
g f t J - y 'l f;,
1 N,_,l '
( (
l With the issuance of the noncomformance report, No, 1482, on Augus t 18, 1978,-CPCo'was.also informed o'f this condition. On or about August 21, 1978,-the SRC Resident Inspector was orally' informed of the matter by C?Co. It was indicated at that time that although CPCo regarded the ,
matter as serious, they did not consider it to be reportable under
~
Construction on the DGB was.placed on. hold on August 23, 1978.and a test boring program was initiated on August 25, 1978. After prelim-inary evaluation of soil boring data, .a dbnagement Corrective Action
- Report ,(MCAR) , No. 24, was issued by.3echtel on September 7,1978.
The EMCAR stated that based on a preliminary evaluation of the data, '
the matter was reportable underfl0' CFR 50. 55(e), 1, iii and Region III was so notified by telephone on that date.
The telephone notification was subsequently followed up by a letter
' dated September 29, 1978, from C?Co enclosing a copy of MCAR 24 and "
-' Interim Report 1 prepared by Bechtel.
. On che basis of the above,'it is concluded that.in this' instance the
. licensee . complied with the reporting requirements of 10 C7R 50.55(e) .
Review of ?SAR/FSAR Commitments on Comoacted Fill Material-
/~3 4 In-a previous SRC Inspection Report, Yo. 329/78-12; 330/78-12, an f apparent inconsistency was identified ,between FS AR Table 2. 5-14
-(Summary of Foundations Supporting Seismic Category I and II Structures),' . ,
Table 2~.5-9;(Minimum Compaction Criteria) and the. site construction ,
' drawing C-05 (Class I Fill Material' Areas) regarding the type of foun- .
dation eaterial to be used for plant area fill. Table 2.5-14 identifies the supporting soil materials for the Auxiliary Building D, E, F, and G. Radwaste 3uilding, Diesel Generator Building and Borated Nacer Storage Tanks to be " controlled compacted cohesive fill." Table 2.5-9 also indicates the soil type for " support of structures" to be clay.
Contrary to these FSAR commi;3ents, drawing C-45 indicates 2cne 2 i (random fill) material, defiud in Table 2.5-10 as "any material free of humus, organic or other deleterious material," is to be used with "no restrictions on gradation." Boring samples substantiated that Zone 2 (random fill) material was in f act used.
2uring this investigation a review of.documentatica showed that che'
~
g.
commitment to use cohesive soils was also made in respcase to ?SAR question 5.1.11 and submitted in ?SAR Anendment 6, dated December 12,
'1969, which' states, " Soils above Ilevation 505 will be cohesive soils in an' engineered backfill." This response also-indicated that certain class ! components such as, emergency diesel generators, borated water a
t storage' tanks and associated piping and electrical conduit would be founded on'this racarial.
t t
\ -t
- 3. .
J.b .t e
e 4 , .-evr,- y ,, . ..,+--,,e,w,w- .,,.w=-r- ww,,,,,, .r,4 w,,w,,.i w, ,~e.-e w r -e-e v -e N,ve.-**w vptw + wo v e e w- e e* vm -we
N- /
CPCo quality assurance issued a nonconformance report QF-66, dated October 10, 1975, which stated that contrary to the PSAR statement (quoted above) Specification C-211 being implemented at the site
' required .:ohesionless (sand) material to be used within 3 feet of the walls of the plant area structures. The corrective action taken was for Bechtel to issue SAR Change Notice No. 0097 which stated, "The FSAR will clarify the use of cohesive and cohesionless soils for support of Clara 1 structures." As noted above, the FSAR tables ?. 5-14 anc 2.5-9 once again stated that cohesive (clay) material was used for support of structures while the construction-drawing continued to permit the use of random fill material.
This investigation included efforts to ascertain whether procedures were established and i=plemented for the preparation, control and review of the technical criteria set forth in the safety analysis report (S AR) .
This included the role of both Bechtel and CPCo in the review of the SAR. Bechtel had established control of the SAR in procedure MED 4.22 (Preparation and Control of Safety Analysis Report Revision 1, dated June 20, 1974). The SAR preparation and review flow chart requires the Engineering Group Supervisor (ECS) to review the originator's draft for technical accuracy and compliance with the standard format guide.
Records indicsted that Section 2.5.4 was originated by the Bechtel Geotech group on January 3, 1977. It was reviewed and approved for technical j-'s accuracy by an engineer in the civil project group on April 29, 1977.
No technical inaccuracies were noted in the documentation. The Civil (A
s- ) EGS advised that he did not personally review Section 2. 5.4.
The designated engineer -cated that in his review of the section he was primarily concerned w: th the Auxiliary Building not the Diesel Generator Building. He sa d the review of FSAR material was performed by members of a group set .p for this purpose. Not all of the content was checked since they rel.ed to some extent on the originator. The author of Section 2.5.4 said he was not aware that changes regarding fill. material had occurred since the preparation of the PSAR. It was iscertained that Field Engineering did,not review the TS AR prior to its submittal.
A partial review of the FSAR revealed that although Figure 2.5-13 indicates anticipated settlement of the Diesel Generator Building during the life of the plant to be on the order of 3 inches. Section 3.3.5.5 (Structural Acceptance' Criteria) contains the following state-ment: " Settlements on shallow spread footings founded on compacted fills are estimated to be on the order of 1/2" or less."
Section 3.9 was prepared by Project Engineering. Geotech, who prepared Section 2.3, said they were unaware of the presence of the statement regarding 1/2" settlement in Section 3.3. The originator of Saction 3.3
/'
i N/ _ _
1 1
1 1
1
/~* N IV) .
( (
said that the above statement was taken fror the Dames and Moore report ;
submitted as part of the PSAR. Since the PSAR did not show any change I in this regard, he' assumed the statement was valid for inclusion in the FSAR. He said there.was no other basis to support this statement.
CPCo also has an established procedure for the review and final approval of the S AR by procedure MPPM-13 dated June 23, 1976. Section 5.6 states that "CPCo shall approve all final draft sections of the FSAR orict to final printing." Discussion with th.e responsible licensee representa-tives for review of Section 2.5.4 indicated that a limited amount of cross-reference verification of technical content of the FSAR is
' performed by CFCo.
The CPCo Proj ect Engineer in Jackson stated that the review of drawings and specifications was an owner's preference kind of thing. No attempt was made to review ull drawings and specifications since they did not have the manpower or expertise for that type of review. The staff engineers of the various disciplines were asked to indicate the drawings and specifications they wanted to review.
Regarding the review of the FS AR, he said that he had prepared a memorandum to the staff engineers stating the procedure that would be followed in performing the review. An examination of this memo, dated r
7'^'g July 28, 1976, showed that prime reviewers woeld perform a technical ,
$ j review, resolve comments made by other reviewers and perform the CFCo I
\s d licensing review to assure compliance with required F5 AR format and e.ontent. ,
As portions of the FSAR were received from Bechtel, CFCo sent comments to Bechtel. Following this review, meetings between Bechtel and CPCo were held to clearup any unresolved matters before each section was released for printing. A review of the files at CFCo relating to Section 2.5 and 3.8 showed that no comments were made concerning the above inconsistent and incorrect content. The apparent inconsistent l and incorrect statements were not idencified during the review of the FSAR prior to submittal and the review procedures did not provide any mechanism identiff apparent inconsistencies between sections of the FSAR.
Based en the . .ve, measures did not assure that design basis included in design drawings and specifications were translated into the license application which resulted as an inconsistency between the desi;n drawings and the FSAR. This is considered an item'of noncompliance with 10 CFR 30, Appendix 3, Criterion II!. (329/73-:0-01; 230/73-20-01) i i
t l
i
, gg I I
!x-_ /
t
_3_
/~' .t
. (
(
Ef fect of Ground b'ater in Plant Area Fill Final plant grade willLbe established at elevation 634 The normal ground water was assumed to be at ground surfaci prior to construction, ;
approxi=ately elevation 603 .The surf ace of the water in the cooling water-pond will be at a maximum of approximately elevation 627.
The Dames and Moore report on. Foundation Investigation submitted with PSAR' Amendment No.1, dated February 3,1969, stated t hat, "The effect of raising the water level to elevation 625 in the raservoirs will cause the tormal ground water level in the general-plant area to eventually rise to approximately elevation 625 However, a drainage system will be provided to maintain the ground water level in the plant fill at elevation 603.
-A supplement to Dames and Moore report %as submitted in PS AR Amendment No. 3,. dated'Auge *. 13, 1969, which changed the above planning of a drainage system t; ancrol the ground water. The supplement states,
,e I "The underd::ainags system considered ~in the initial report has been eliminated;: consequently it'is-assumed'that the ground water level in
.che plant ~ area will rise concurrently to approximately elevation 625."
.A 3echtel soils consul' tant theorized in a December 4, 1978, site meeting
' that= if so.ils beneath the diesel generator. building had been compacted g
' too dry of optimum, chaages in moisture after placemer,t could cause the
' . soils to settle'significantly. .Therefore, the total effect of the
- ground water,being permitted to saturate the plant fill material is
's undetermined at this time. An ' evaluation of this condition is under review by the licensee. This itam is considered unresolved. (329/78-20-02; 330/78-20-02)
Review oi Comoaction Requirements for Plant Area Fill
~# During the-investigation a. review of the history of the compaction rcquirements was performed in order to determine whether the compaccion of the plant fill was implemented in compliance with the commitments in the PSAR and in site construction specifications.
PSAR, Amendment 1, dat(d February.3, 1969, presented.the Dames and yoore report " Foundation Investigation and Preliminary Exploration for 3orrow
' ya t e r ials . " The recommended minimum compaction criteria for suoport of l
critical structures is stated on page 15. It indicates 95% of maximum density for " cohesive soils" as determined by ASTM D-1557-66T and 100T' for " granular soils."
?SAR, Amendment .3, dated Auguat 13, 1969, included a supplement to the Dames and Moore report entitled, " Foundation Investigation and Freliminary b
l i l
l I
.r-. . , - ,_. , __, . _ , . - , _ - - . . . _ . . , . - . . . _ . . , , . _ . , . . . . . _ . . . - - . . - - . . . - - . . . . . _ . . . . . , . . _ ,
,s ',
/
'h !
LJ Exploration for Sorrow >bterials." Page 16 of this repor: lists the reccomended minimum compaction cri:eria for sand soils and cohesive soils.
For the fill material fer supporting structures the minimum compaction is 85% relative density for sand and 100% of maximum density for clay as determined by ASTM 0-698 modified to require 20,000 f t-lbs of compactive energy (equivalent to 95% of ASTM D-1557, Method D which provides 56,000 ft-lbs of compac:1:a energy). Subsequent to the filing of Amendment 3, no amendments were made to the PSAR to indicate that the recommendations contained in the Dames and Moore report would not be followed or would be further modified.
^^"' Bechtel Specification C-210, Section 13.0 (Plant Area Backfill and Berm Backfill) indicates the compaction requirements for cohesire soil (13.7.1) to be "not less than 95% uf maxieu= density as determined by ASTM D-1557, Method 0" and for cohesionless soils (sand) (13.7.2) to be compacted "to not lets than 80% relative density as determined by ASTM D-2049."
A cocparison of the PSAR commitments to the specification. requirements shows that the compaccion commitments for cohesive soil (clay) were translatad into the construction specification i.e. 95% of maxieum density using ASTM D-1557, Methed D (compactive energy of 56,000 f t-lbs) .
However, the compaction commitment in the PSAR for cohesionless soil
! (sand) was not the same as in the construction specification, i.e. 35%
i
=
/
-~s relative density versus the 50% relative density, translated in :he
( ') construction specification. -
x._/
1 l
The compaction requirements actually implerented were as follows:
\
- a. Cohesive soil (clay): 95P. of maximum density as determined by the "3echtel Modified Test," a compac:ive energy of 20,000 f:-lbs was used instead of 36,000 f t-lbs of compactive energy as committed to in the PSAR and required by the construction specification C-210,
-~ W . . Section 13.7.1.
(
- b. Cohesionless sc U (sand); 807 rel'ative density as determined by ASTM D-2059 was used instead of S5P as c0 emitted
- o in the ,
PSAR. However, this is consistent with construe:icn specifi-cation C-21), Section 13 7.2.
l The compaction requirements implemented du' ring constru::icn of the plan:
area fill between elevations 603 and 635 were, therefore, less than the commitments made in the'?SAR for cohesive and cohesionless fill material. :n additon, the cohesive (clayi eaterial was also(Specification cor.pacted
- o less :han : hat required by :Se 3echtel specifica:Lon.
C-210, Section 13.7).
i (s_, ;
I 1
l l
l l
1
f%. (
1 N~- ,
A review of Specification C-210 (specification controlling earthwork contract) beginning with Revision 2, dated July 27, 1973, which was issued for subcontract showed that it contained conflicting sections relating to the plant area backfill compaccion requirements.
Section 13.7, Compaction Requirements, from revision 2 to the latest revision of specification C-210 consistently specified that the backfill in the plant area shat! be compacted to 95% of maximum density as deter-mined by ASTM 1557, Mecued D.
Section 13.4, Testing Plant Area Backfill, of specifi:ation C-210 con-
" ' ' " " tained the statement that tests would be performed as set forth in Section 12.4.5, Laboratory Maximum Density and Optimum Moisture Content, which in turn specified a lesser standard, 20,000 foot-pecnds per cubic foot, which is commonly referred to as the Bechtel Modified Ptoctor Density Test (EMP). This is contrary to the requirements of Sectior. 13.7.
Section 12 of the specification applies to Dike and Railroac E=bankment Construction.
It was also noced that this control inconsistency was reflected in the applicable Midland QA Inspectioc Criteria, SC-1.10, Item 2.3(d) Compaction which states " Backfill material for the specified tones has teen compacted to the required density as determined cy Bechtel Modified Proctor Method" L -~s and yet references C-210, Section.13,7.as the inspection criteria.
t / s s ,/ ~ he inconsistency in control is further indicated in Specification C-208 which defined the testing 'contrac". requirements of subgrade materials ,
Section 9.1 (Testing) required compaction tests to be in accordance with
' ASTM D-1557 and only when directed was the SMP compaccion criteria to be used. It was determined contrary to this U.S. Testing was only orally advised that the BM? was the standard to be applied to the tests they performed of plant area fill.
<
- c' Through interviews and an examination of internsi documents it was 1scertained that because of th,ese incon,sistencies, the question of che applicable compaction standard for cohesive materials in the plant area was a recurring one.
The following is a summary of the documentation regarding the confusion of the compaction requirements for plant area fill:
l i
- 1. Letter 7220-C-2LC-77 dated June 10, 1974, (subcontracts to Field Engineering) states "there has been some confusion as to the inter-precaion of the following item: 13.7 Comoaction secuirement: all backfill in the 7 tant area and berm shall be compacted to no t less than 957 of maxicum density as determined by modified ?roctor met'. icd
/
x_ - _ . . .
G e .-e- -
, w , , +- = , - -
i 7-n s
( (
~
i _, )'
( ASTM 1557, Method D), with the exceotfon that Zones 4 4A, 5. 3A.
and 6 Materials need no special compactive ef fort other than as described in Section 12.8.1 (emphasis included in specification).
Quality Control questioned whether the exception stated above applies only to Zones 4, 4A, 5, SA, and 6 or did construction have to abide by Section 12.8.1 for Zones 1 and 2. Section 12.8.1 clearly requires Zone 2 material to be placed with a 50 ton rubber tired roller with a minimum of four roller passes per lift. Q C '.s interpretation was that the field needed "to obtain 957 of maximum density by the modified Proctor method (AStt 1557, Method D), with no restrictions as to the method used to obtain these results."
- 2. Letter 7220-C-210-23, dated Juna 24, 1974, (field Engineering to construction) responded to Item 1 above. It states , "We have reviewed your June 10, 1974, ICM concerning compactive effort required on Zones 1 and 2 in the plant and berm backfill areas.
We agree with your interpretation; i.e. a 95* of maximum dens'ity is the acceptance criteria, and the number of roller passes listed in Paragraph 12.8.1 does not apply to plant and berm backfill. We feel.the specification is now clear and no FCR is required."
- 3. Letter 3CBE-370, dated July 25, 1974, (field construction to project engineering) lists outstanding items requiring Project
, s. Engineering's action. This includes the question, "Is the 95*
( \ compagtion required in the plant area to be 95% of Bechtel
\ Modified or 95". of ASTX-1557, Feched D."
i l
- 4. Letter BEBC-456, dated August 1, 1974, (Project Engineering to Field Construction) states that Geotech is addressing the question posed in BCBE-370 (Item 3 above).
- 5. Memorandum from Geotech to Bechtel Field, dated September 18, 1974, responds to the question raised in 3C3E-370 (Item 3 above). It states, "It is cur opinion that all the compaction requirements that are needed for Zone II material in the plant fill is as stated in 13.7 with the exception that Tones 4, L'A ,
5, 5A, and 6 materials need no special coepactive effort other than described in Section 12.8.1." Geotech reiterates the specification requirement of 952 of ASTM 1357, Method D. This was confirmed with the Geotech personnel.
-5. Telecon dated September 9, 1974, fr:m F., Crete (Field Engineering) to Rixford (Proj ect. Engineering) states, "I made an analogy (an exaggeration admittedly but applicable) that if the compaction could be acheived with a herd of mules walking over the fill it would be acceptable as long as it got the required 95% compaction.
Rixford agreed."
i r%
i t i v _ ,,
t
,~
7 l
.s 1
/
' \
v
- 7. Telecon Consumers to Bechtel Engineering dated September 19, 1974,-
expressed Consumers Power Company concern about what they felt was a lack of control of compaction in the plant area fill. CPCo addressed the added responsibility this lack of control places on the inspector. Bechtel cold CPCo that it "was the inspector's job to make sure we got proper placement, comoaction, etc."
- 8. Telecon dated September 18, 1974, by Bechtel Field Engineering to Bechtel Project Engineering discussed compaction requirements for specification C-210. It stated, " Compaction acceptance is based on meeting an 'end product' requirement, i.e. 95% of maximum density only. No method of achieving this 'end product' is specified or is required. Rixford fully agrees with the above "
- 9. Telecen dated October 7, 1977, from Bechtel Field Engineering to Bechtel Project Engineering states, "QA has asked for clarification of subject specification (C-210), Section 13 for plant area and berm backfill. Section 13.4 for testing of materials refers to Section L2.4 and therefore, requires the Bechtel Modified ?roctor Density Test for Compaction of cohesive backfill. Section 13.7 for compac-tica of the same materials refers to testing in accordance with ASTM D-1557, Method D Proctor, without specific reference to 3echtel Modification." Bechtel Engineering responded to :his question as f~ g follows: ",This apparent conflict is clarified by Specification C-203, Section 9.1.a. direction to the testing subcontractor, (N_ /) which calls for ASTM D 1557- test for these materials and also
- l. allows Bechtel Field (the contractor) to call for the 3echtel Modification of tha: tes:. Either method is therefore acceptable to pecject engineering."
- 10. Telecen dated October 7.1977, from Bechtel QA to Bechtel Project Engineering questions, "13 the intent of Paragraph 13.7 of Spect-fication C-2!0 that the tesc be run to the 'Sech:el' modified proctor test as is indicated in the ~SAR Paragraph 2.5.4.5.3 and in response to yCR 33." Engineering's response was "yes."
Various interviews were held wi:h Bechtel cens:ruction field engineers, l'. S. Testing personnel and 3echtel Ann Arbor Geotech and ?roj ect l Engineering personnel to ascertain : heir understanding of the compaction l
requiremen:s. Tour predtminan: versions of :he unders:ced compaction requiremen:s vere stated by various individuals ui hin :he 3echtel
! ~*;ani:a: ion. They are as follows:
l l a. Specificati:n C-210 required :he con:rac:or to perform
- ompac: ion :o :he AST" 1557, Me: hod D. however, the :esting recuirements would be performed to the less strinzen: "Sechtel Modified Test ".e: hod."
m fs k, .
'- '- l l
1 l
l 1
I -
t 1
_,...mm..., _ . . , . . . - , . . , . . . _ , , _ . , , _ .,-e, .
t '
_4 e
5
-( (
- b. The required compaccion and-cesting was always understood co be based on the "Bechtel Modified Test Method."
S c.- The required compaction and testing was always understood to be
. based on the standard ASTM 1357, Method D requirements, d.3 A tacit understanding had been established to use the Bechtel Modified. Method, but to exceed this requirement by enough
- to also satisfy the requirement of ASTM 1557, Method D. -
, ,j It is apparent from the above four distinctly different understandings of che compaction requirements. that the apparent confusion was not resolved. A member of the. Bechtel' QA staf f in Ann Arbor. who had previously been a QA Engineer at the Midland site said that'QA audits of QC inspection criteria did not identify the above inconsistencies.
This failure to accomplish activities affecting the quality of the plant area fill in accordance with procedures is considered an item of noncom-
- pliance with'10 CTR 50, Appendix B, Criterion V. (329/73-20-03: 330/78-
. '20-03)
Review jf Moisture Control Requirements for Plant Area Fill
~'
Specification C-210, Section 13.6 (Moisture Control) requires moisture 7/ ' control of the plant' area fill material to conform to Sectiog 12.6.
1 The moisture' control ^ requirement'in Section 12.6.1 states, in part,
" Zone I, IA and 2 material ~which require moisture, control, shall be moisture. conditioned in the borrow areas," and that " water contentLduring compaction shall not be more chan two percentage points
, below optimum moisture content and'shall not be more chan two percen-tage points above optimum moisture content."
1 . Contrary' to the above, Bechtel QA identified in 5D-40 dated July 22,
'^6 - 1977, that "the field does:not take moisture control casts ' prior to and during placement of the backfill, but rather rely on the moisture a
1 results taken f rom the in-place soil density tests."
The following is a summary of the documentation that -followed the
. identification of the above deviation from specification C-210.
- 1. Letter BC3E-1533R (dated August 15, 1977) field to project engineering states, "it was found that densities meetin; specification require-ments could be attained, irrespeerive of the use of moisture tests,"'and' chat " moisture tests were not used to control backfill moisture."' The field requested "that p roj ect engineering a7:ce to acceptance of backfill materials installed in the past, along with
~
the records thereof, irrespective of the use of the moisture tests."
- li -
f f
rv gw-,,-,Syy + s--- rr gr- g e w -p -wy v-fr ge' y yov' gr v f y wy g g4i,yv.,,,=ey<ms,,w,=+- ,q .g er +e W *t- s t" u*' e W 9eterW at
- P'e 84**Ms'*T-9 Steam-m-1'v--e"S-mwe'r*--r'9 e w'r e sp er W 6- ie v e mwr*w- 4pe e e=*'e *M 9* W'v e w t
- e *U
- w. j 'F !
31 -
- e. .
.O
.t
./..
g
- 2. Letter BEBC-1859 (dated September 30, 1977) responsed to the fields req'uest in,BCBE-1533R,1 Engineering' states, "It should be noted that it'is ideal to centrol the moisture of backfill. material at the borrow areas by conditioning" and that."the; procedure used to
- take moisture content tests.after compaction would not have' direct impacc on theequality of work." Engineering then agreed with the p ~ field request .that " backfill placed prior - to modipication of testing metho,ds'to be accepted as is." - j1 1
- 3. Telecon Oct'ober 10,1977, (Sechtel' .QA Site to .3echtel Engineering, Ann Arbor) indicated that,""thero are no moisture requirements at
"" the time :of density testing, only- density requirement. The-moisture '
'requirementiis prior to compaction."
4
'4. .Telecon October-13,1977, (Bechtel Engineering to Bechtel OA Site) changed what was indicated in.che telecon on October 10,.1977,
'/(Item 3 above). . Engineering then's tated , "The mois ture , require-ment (+, 27. - o f op timum) is mandatory and must be . implemented at
.the. time of' placement and testing." This is contrary to what~was stated ~on October. 10,:1977.
- 5. Letter 3C3E-1669R (dated'Sovember 18', 1977) once.again is a field request to Bechtel'-engineering requesting, " written clari-fication' of the 27.- tolerance on backfill moisture content 'during s s compaction."
6'. Lett'er BEBC-1998L(dated December 15, 1977) provides engineering's response ta BC3E-1669R requesting clarification of the moisture requirement. . Engineering stated, "The moisture content of the soil should .be within 27. of optimum during placement and compaction.
l' 1h'
~
However,'this property of the soil is not necessarily a measure of ,
its adequacy after compaction."
- 7. Letter 0-1631 (dated December 21, 1977) closes OA Action Request
- S0-40 (dated July 22, 1977) which first identified the moisture con, trol deficiency.
- 8. Telecen (dated Ap'ril 7, 1973) from Field Enginaaring and Ouality r Control to Project Engineering once again requests them "to clarify BEBC-1998" (December 15,. 1977), Item 6 above. Two situations were presented to engineering as .follows: (a) The moisture sample taken from the borrow area at the start of the shift is acceptable,
.however,Jthe moisture te.st taken in conjunction with the density
' test f ails while cocoaction was attained; and (b) The noisture sample taken fecm the bar:cw arsa-at the start of the shift fails and'che' material'is conditioned to meet moisture content required.
. m bm#
j i
.)
1
. ... m .. .. . . - . . , - - . . - . . _ ~ , . . . ,.:..._..,.w_. .....-m.-._,-,- ,-..~.e,..._,,,....--
. . . - . - -. - - .. . .. . . _ . ~
1 1 _[ :, .
[ l
% f however,.the moisture test later fails at the time the passing compaction' test is taken. Engineering responded, "the above two l situations are acceptable as is." This response is contrary to the direction previously-given in telecon dated October 13, 1977 (see Item 4 above).
.9. Letter CLR-249 (April 16, 1978) is a Bechtel Site QA-request to Project ' Engineering to resolve tne moisture content situation and'"co provide clear direction for the control of moisture 4 content." QA recommends "one possible solution would be to delete the requirement-to control the moisture content and rely
'~~~"~
on the compaccion requirement only for completion of soils work."
- 10. Letter 3 ESC-2236-(June'1, 1978) was Project Engineering's response to GLR-249 (Item 9 above). It states " moisture content is not necessarily a measure of a ' soil's adequacy to 'act as a foundation i or backfill material," and that " soil with the specified density following compaction would not be rejected or. the basis that its
-moisture content was not controlled in the borrow area."
_3ased on the reviews of documentation, moisture control had not been implemented'as the specification required. In addition, the matter-
.l had not been resolved for the period of time from the issuance of QA
,<-L 1 Action Request SD-40.on July- 22, 1977, until June, 1978, during which
'lt time soils safety-related work continued. 4
)~ n
.According to the licensee, although moisture control was not strictly followed in accordance with specification require =ents, final censity .
tests were used as a basis for acceptance of soil placement.
As pointed out to the licensee, moisture control is a required control point-to assure attainment of percent compaction specified in specifi-l~
cation C-210.
' This f ailure to assure that . conditions adverse to quality are peceptly identified and corrected to preclude repetition is considered an item of noncompliance with 10 CFR 30, Appendix 3. Criterion XVI. (329/73-
- n. 20-04; 330/78-20-Os)
Review of Sub2rade ?recaration for plant Area fill L ,
The Dames and Moore report on . foundation investigation submitted with
?SAR Amendment 3, dated August 13, 1969, states. "the clay soils are L
l susceptible to loss o'i strength due to frost action, disturbance L
and/er the presence of water. If the construction schedule requires that foundation excavation be left open during the wintar, it is recommended that excavation operations be performed such that at least i
P V _n_
, - , . - , . . . , . - . , , . . . , . . _ - . _ . _.m...., .. ,...__-.~-._.., ._,,.. ..- ,. . . - _ . . . . , - ..~..%.,......~,...--.....
4 m
i -
(~
Ns_-)1
)
3 1/2 feet of natural soil or similar cover remain in place over the final subgrade or overlying the mud mat. This layer of prot;ctive material is necessary to prevent the softening and disturbance et subgrade soils cue to frost action." The licensee indicated that instructions for winter protection of foundation excavations were trans-mitted by sketch C-271.
The Dames and Moore report also stated, "If filling and backfilling operations are discontinued during periods of cold weather, it is recommended that all frozen soils be removed or recompacted prior to the resumption of operations."
After review of the tpplicable secticos of specification C-210 (i.e.
~
Sections 12.5.1, 12.10, 10.1 and 11) the inspector has determined that the Bechtel specification did not provide specific instructions for removal or recompaction of frozen / chawed soils upon resumption of work after the' winter period to preclude the effects of frost action on the compacted subgrade materials.
This failure to assure that regulatory commitments as specified in the license application are translated into specificLtion, drawings or instructions is considered an item of noncompliance with 10 CFR 50, Appendix 3, Criterion III. (329/73-20-05; 330/79-20-05)
, ~~s .
(s 'l Review of Nonconformance Reports Iden,tified for ?lant Area Till l /
v.
l The following examples of nonconformance and audit reports regarding i che plant-area fill were reviewed relative' to the cruse of the noncon-formance and the engineering evaluation and corrective action:
No. Nonconf o rmin2 Condition Engineering E'aluation (1) CPCo Failure to per'orm inspec- "Use as is" based on QF-29 tion and testing of struc- samples taken from stock l (10/11/74) tural backfill (sand) pile.
delivered to jobsite 29 of 30 day in Aug. and Sept.
l I 74 3echtel QC not informed of deliveries.
(2) CPCo Moisture contr:1 out of Accepted in place material QF-32 colerance of specifica- with low mo is ture.
(3/7/75) tion C-2'0,
, Section 13.6.
( 3) C?Co Compaction test had been Failing tests were cleared QF-63 calculated using incor- by suosequent passing (10/17/73) rect maximum lab density tests.
Test recorded as passing was actually a failure.
,~
f \
\% '/ -p-l
s .
I (
V (L) Sechtal Material placed uid not Engineering stated that
%'CR 421 meet. moisture require- this ramp area is temp-(*/5/76) s ments. orary and would be removed.
This was removed based on note added to SCR 121 on 3/18/77.
Note: In the vicinity of this ramp a Geotech engineer deter-mined the matccial to be " soft" and directed a test pit to be dug for investigation in September 1973 after the D. C. 31dg.
settlement uas identified.
'5) C?Co Lift thickness exceeded interial was removed and QF-120 maximum of 4" in areas recompacted.
(9/21/76) not accessible to roller equipment. Insufficient monitoring of placing crews. Laborer foreman not faciliar with re-quirements. .
(6) CPCo Inspection plan C-210-4, Corrected inspection p* c an QF-130 Rev. O, permits 12" lift requirements.
-s .(10/18/76) thickness for areas in-
/ \ accessible to rollers (s_,) caused by "misinterpre-i cation of specification requirements. Spec, per-mitted 4" lift thickness.
(7) CPCo Failure to perform inspec- Engineering accepted the QF-117 tion and testing of struc- material in place "use (2/2/77) tural backfill (sand) on as is."
12/1/76, 12/14/76 and 1/11/77 (same as QF-29 dated 10/14/74) material lacked gradation test requirements.
(3) CPCo Moisture control out-of- Engineering accepted QF-172 colerance and compaction materials.
(7/3/77) criteria no t met.
l l (9) C?Co Gradation require ents Engineerin; accepted QF-17a for Zone I materials not materials.
f,7 /15/ 7 7 ) met.
fe~'y i ; 1
'd 13 -
t i , , _ - __ . _ ,_, ,, __
-s t
/ i- t i
\.
(10) CPCo- Moisture content not met; Issued Bechtel NCR's No.
compaction requirements 1004 and 1005; No. 1004 QF-199 (11/a/77) "or cohesive and cohesion- still open; No. 1005.
1ers soil not cet. >ta t e r- "eccepted as is."
tais had been accepted using incorrect testing data.
(11) CPCo Gradation requirement not Engineering " accepted QF-203 met yet materials accepted. as is."
(11/22/77) i (i2) C?Co Moisture content require- 3echtel QC to inform j
.tud it - ments not met; test fre- fotecan directing soils l F-77-21 quency not met, work of requirements.
(3/77 &
6/77)
(13) CPCo Compaction requirement for Project Engineering :o Audit both cohesive and cohesion- justify the materials F-77-32 less caterials not met; these failing tests (10/3/77) moisture req 2irements not r3present. NCR QF-195 met; tests had bten accept- still open.
-s s ed yet failed requirements. ,
,/
- Same deficiency as NCR 698. Accepted, "use as 16."
I
\s,,- (l')' Bechtel NCR 686 (2/1/77) .
(13) Sechtel Structural backfill (sand) Engineering accepted NCR 693 was delivered without "use as is."
(2/9/77) acceptance tests en Oct.
26, 29, Nov. 12, 1976 and Jan. 11, 12, 1977.
(16) Bechtel Moisture centen: require- " Accepted as is" based On
. NCR 1003 cents act ee:. densi:y test only (10/26/77) 3ased :n 2 r e viet. ef :he abeve n:nconfor:2n:e and audi: re;cr:s :rrre:-
- ive ac:ica reg 2rdin; nen::aferrances reia:+d :: pian: fill was insu:fi-
- ien: er inadequa:e as evidenced 5: :he repea:ed devia:icas firm spect-fication-requiremen:s.
his failure :: assure :ha: :he cause :f ::ndi:icas adverse : quait:"
are iden:ifi43 and tha: 3dequale Orre::ive 1::i:n 'r3 03 hen :: Ori:.ude O
t
\
% - - ;? -
1 l
1
2 l
l 1
n l
\
l.
/
(
%s repetition is considered an item of noncompliance with 10 CFR 30, Appendix 3, Criterion XVI. (329/73-20-06; 330/73-20-06)
Review of Calculations of Settlement for Plant Area A review of the secclement calculations Lfor the structures in the plant area was performed during a visit to the Bechtel, Ann Arbor Engineering office. Specific attention was given to structures founded on plant area " compacted fill." The following specific findings were made:
- 1. FS AR, Section 3.8.4.1.2 (Diesel Generator Building) indicates the foundation of the DGB to be continuous footings with inde-pendent pedestals for each of the Diesel Generators. Con::ary to the structural arrangement described in the FSAR, the settle-ment calculations for the DC3 were performed on .the premise that the building and equipment loads would be uniforuly distributed to the foundation material by a 134' x 70' foundation mat. The settlevent calculations were performed between August 1976 and October 1976 by 3echtel Geotech' Division.
Discussion with :he Geotech Engineer who performed the settlement calculations indicated that he had not been informed of :he
- design change of thi foundation until late August 1978 when the
[ sgj excessive settlements of the DGB and pedestal became apparent.
\g
- 2. FSAR Figure 2.5-47 indicates the load intensitv for the CGB to be .
4 KSF (4000 lbs, per sq. f t.); however, the set:lement calculations reviewed indicate a uniform lead of 3 KSF (3000 ?ST). This appears .
to be a conflict between the FS AR and settlement calculations.
3 The settlement calculations for the borated water storage tanks were performed assuming a 54' diameter circular foundation mat with an assumed uniform load of 2500 PSF. Instead, the tanks are supported on a continuous circular spread footing and Compacted s:ructural backfill as detailed on the construe:Lon drawings.The Geotech engineer was also not made aware of :he revised foundation detail.
FSAR Figure 2.5-a3 (Estimated Citimate Settlements) indicates the an:icipa:ed ultimate settlement f o r '.'n i t I and 2 plant stru::ures. The
/21ues indicated for :he Diesel Genera: r Building und 3 crated iater Storage 'Janks are the values developed assuming uniformly dis:ributed loads fcunded en mat foundations as was indicated in the set:lerent calculations reviewed even : hough the actual design and construe:icn u:ill:es spread fo6 tings. The FSAR does no: indica:e the fcunda:10n X
l V
-V, - .: 0 -
4
, ~ . . . , . ,,, - - . _. ~ ,
. - . . . . . _ . _ . _ _ . . _ , - - - . ~ .
,,3
/ \
\ : %
( ./
type assumed in the settlement calculations and :herefore the values in the FSAR figure appear to represent the settlements estima:ed for the as-constructed spread footing foundation.
4 Durira a review of the settlement calculations, it was observed that the compression index (C ) for the compacted fill between elevations 603 and 634 in the plant area was assumed to be 0.001 (estimate based on experience) . FSAR Section 2.5.4.10.3.3 (Soil Parameters) indicates the soil compressibil( y parame:ers used in the settlement calculation are presented P. Table 2.5-16.
-- e This table indicates that for the plant fill elevations 003 to 634, the compression index used was 0.003. Contrary to the FSAR value, 0.001 was used in the settlement calculations reviewed.
This value is directly used to deternine the estimated ultima:e settlecent of structure supported by plant fill material.
Based on the above examples, measures did not assure that specific desi2n bases, included in design documents, were translated into the license application resulting !.n inconsistencies betueen desitn docu-cents and the FSAR. This is considered an 1:em of noncompliance with 10 CFR 50, Appendix 3, Criterion III. (3:9/73-20-07; 330/78-20-07)
Discussions vich CPCo personnel responsible for :he technical review 7s and format indicated that a comparison between the design documents l } and TSAR had not been performed. Likewise, 3echtel personnel indi-
\ ,/
cated that a detailed comparison for the technical accurscy of design l' documents to the FSAR sea:enents had not been performed; instead reliance was placed on :he originator's input.
According to the Civil Engineering Group Supervisor, a cat foundation was considered for the 0G3 only during the concep:ual stage. All drawings generated show a spread foo:ing fcundation. The super ~isor s: aced : hat the Geotech engineer apparently based his calculations on l the conceptual stage information. He ven: on to say that an individual I in Geotech was responsible for checking the calculations and the first
! :hing he is supposed to do is determine tha: :he basis for the calcu-lations is correc:. He said that apparently this was not done.
Review of Se: lement of Administration Buildine "cotin29 f Ouring :he investiga: ion, it was disclosed that the Adminis: ration l Suildinz a: the Midland Site had exoerienced encessi'v2 se: lenent of l
- he foundation foo:ings. Although :he Admints:::: ion 3uildinz ir a j nen-safety talated struc:ure, i; is supper:ed by pl:n: area fill l
na:erial cerpac:ed and :ss:ed to the sa e recuiremen:s as ra:erial I i
\ /
x' _ 21
- . , - - ~. .,. . . - - . . -, -
I - '4 '
g
, o 3
T 3
A ..%
i
( (
.-supporting-safety-related structures and therefore pertinent to the e
current settlements being experienced by the Diesel Generator Building.
.The'following are the events relating to:che settlement of the Admini- l o4; stration Building' footings.
. r?f 4
'DuringLehe en'd'of August, 1977, a Bechtel field engineer observed a gap.
- .between a slab and the grade beam of the Administration Suilding. On August 23, 1977; a survep was taken .of _ the settlement. The results indicated that. the footings supporting the grade beam had experienced -
.steclement ranging from 1.32" (north side) to 3.48" (south side).
I V This settlement ~took place' between July 1977, 'and the e'nd of August .
'"" h '1977. The footings:were-supported by " random fill"-(Zone-2 material).
y The ! concrete footings' on the order of 7' 6" by 7' 6" by l' 9"l deep
> ,were removed'along with the grade beam. The ran'om d fill-material was also. removed. 'According to C. S. Testing personnel, it was observed y during excavation of the fill material'that there were voids of 1/4" - s to 2" or.3" within'the fill and these were associated'with large lumps ,
of unbroken clay measuring up to 3 feet in diameter.
1The Civil Field Engineer assigned responsibility for plant fill work said that, although he was no soils expert, it was his opinion that the problem was caused by the presence of pockets of water due to drainage
, ~
from'the steam tunnel. The Lead Civil Field Engineer also indicated ,
t/ a drainage' problem-caused the Administration Building footings settle- -
MA ment. They were, however, unclear as to how the water pockets were , ,
formed..i.e..whether they were' formed as the fill was being placed or how they could' develop _after the. fill was compacted.
T*ne excavated fill was replaced with concrete land the desism of individual footings was i changed to a continuous spread footing i design for support of the' building.
.c As a result of the settlement of the Administration Building footings a total.of seven borings.were taken of which five were in the Admini-stration Building area, one in the Evaporator Building area and one south of the Diesel Generator Building. In the Administration Buildinz 1 area 'the foundation material was found to be. "sof t" with " spongy char-acteristics." The two other borings did not- indicate unusual material
.propertiss.in that the blow counts were reasonable. These borings were taken in September 1977.
~
- The' licensee indicated.that reports from 3echtal concluded that the primary-cause of :he settlement in the Administration Building area was. insufficient compaction o f the fill. Bechtel!also concluded that
" " deviations from specific conpaction requirements was the result of i
-~s ,
y :'
s . :t -
.}
l
.-_c,-~.r_,...
3
,_,c,.,%,.,,.,.._ . . , _ _
t 1, 1 l l
%J l repeated erroneous selection of compactior standard," 1.e. the incorrect optimum moisture-densi:y curve was used for the soil material being l compacted. In effect, the moisture-density curve was erroneously assumed l to represen: the soil being used aad therefore soil was compacted to less l than maximum density.
Bechtel personnel, including the Civil Group Supervisor, Project Engineering, :he Field project Engineer, the Lead Civil Field ingineer, and the Chief Civil CC Inspector, all stated that the Administration Building footing settlement was regarded as a locali:ed problem. The question as to the adequacy of the entire plant area fill did no: arise even though the following sinilarities exis:ed between :he Administration
-3uilding area and res: of plant fill; (a) same soll specification applied, (2) same =aterial (random fill) vas used and (3) same con:rol procedures and selection of laboratory compaction standards was used. The 01esel Generator Building area required even more fill than other saf ety-related structures since its base is loca:ed at a higher elevation than the others.
Review of Interface Between Diesel Generatar 3uildin: Foundation and Ziectrical Duct Banks A review of the design interface between the electrical and civil sections
,_s of the 3echtel organi:ation was performed to determine whe:her the
) design accounted for the intera: tion of the electrical due: banks and i,'~,/ spread footings on :he differen:ial settlement of the northside of the OG3. It was determined : hat the electrical and civil groups made accommodations in :he design to permi: set:lement of the spread icctings arrund :he electrical duct banks by including a styrofoam " bond breaker" around :he due: banks. Both electrical and civil groups reviewed and approved elec:rical Orawing I-302 which includes the aperopria:c de: ail.
However, Sech:el Draving C-L3 which identifies Class I till eaterial areas permits the use of Zone 2 (random fillT which includes "any ma:erial free of hurus, organic er c:her dele:erious ra:erial." This, in effect, does not ) e:lude :he use of cen:re:e ar:und the elec:ri:al due: banks benes:h :he spread foc;in;3. Due :: the diffi:ulty in cor-pa::inz, Zech:el elec:ed :o rerlace :he soil ma:erial eich concre:e.
le::er fr: pr:jec: e;;ineeriar :e fieli cons:ruction, dated Dece-her :*.
19~;, s: stas, " lean c:n::e:e b.:kfill is c:nsidered accep:able for re:la:enen: ci ene ! and 2." The ins:ru::irn is ::nsidered ina:equa:e, in :ha:. :he ::n:re:e ;' acad ar:und the fu:: Sanks restri::ed :he fe" leren: :" he n:r*h side Of the !'~3 *here ele :ri:al du:" banks en:er :hr:::h :he f:::in;. This :r~: rib;:4d :' :n+ a:::e r s t ce :itier-en:'2. fe!!!iP4"
. i: "J.e ..J r :J.- i. .; ~ : irs: i 17 .+ Ine *1ildi??-
/
rs l
\ ..
N_ .. -
1
~
( ,
1
\v/
This failure to prescribe adequate instructions for activities affecting the quality of safety-related structures is considered an.icem of noncom-l pliance with 10 CFR 50, Appendix B, Criterion V. (329/78-20-08; 330/73-
- l. 20-08)
Review of Soils Placement and Insoection Activities for Plant Area "ill l.
l I
A subcontractor, Canonie Construction Company, South Haven, Michigan, performed the major portion of the earchwork at the' Midland site.
Although Canonie was primarily engaged to construct the cooling pond dike, they also performed cost of the plant area fill work. Bechtel, however, also performed plant fill work prior to and after Canonia left the site in mid-October 1977. The last Canonie daily OA/qC fill placerent report is dated October 16, 1977.
According to Canonie QA/QC records the first fill in the DGB area was placed in late October and early Movember 1975. No further fill was placed in'the a,ea until July 1976. After that tire, fill work in the area was interspersed with soils work in other areas.
h*hile it would be difficult to identify the soil work performed by 3echtel versus that performed by Canonie, records reytewed indicated that.nost of the Bechtel, work was done during the latter part of 1976 and continued through l977 and 1973. Although most of the 3echtel work related to placing sand around piping and ducts after they were laid
/%) and placing sand adjacent to walls, some motorized werk coppacting clay
(' ) fill was also done by Bechtel.
Regarding the plant fill work performed by Bechtel, C?Co Audit Report No. ?-77-21 dated June !0, 1977, identified a number of deficiencies which recommended the corrective action to be as follows: (1) "the foremen directing the soils work should be instructed as to the required moisture content limits" and (2) "the foreman directing the u soils work should be instructed as to the correct test frequency requirements." Interviews with t o such Bochtel foremen tonfirmed the fact that they were directing scil operations. They indicated they received their instruction regarding lift thicknesses and testing requirements verbally from field engineering throu2h a general foreman.
3cchtel design criteria C-301 (Page 3) and PSAR Amendment Mc. 3 (Cames and Moore Recort, Page 16) states that, "~illing operations should be performed undar the continuous technical supervision of a qualified sails encineer who would perform in-place density tests in the compacted fill tr '/erify that all materials are placed and crepacted in accordance with the recemmended criteria."
p lq . -y.
i
~
h
~
./~'N d \
V' Based on'the above, the soils activities were not acceeplished under the continuous technical supervision in accordance with Bechtel design cri-teria. This failure to provide a qualified soils engineer to perform technical supervision for activities affecting quality a's required by specifications and the PSAR is considered an item of noncompliance with LO CFR 50, Appendix .B, Criterion V. (329/7'-20-09; 330/78-20-09) 1 1
The foremen indicated that Bechtel Field Engineers and QC inspectors were rarely in the areas where soils activities were going on. The forecen decided when'and where tests were taken. The locations of tests were approximated by pacing or visually esticating dis:ances from columns or building walls. Lift thicknesses were determined visually, usually without the use of grade stakes.
Soils testing services are provided by U. 5. Testing Company based on the requirements of. Specification C-208. The two U. S. Testing tech-nicians who said they performed an estinated 90% of the soil testing during the years 1975-77 indicated tha: they rarely saw a Bechtel field engineer or-QC inspector in :he areas where plant fill activities were ,
going on. One :echnician said he could recall only one occasion when a QC inspector was present when he took an in-place density :es:. The other technician estimated he had con:ac: wi:h a QC inspentor in the field about once a month. A 3echtel QC inspector, however, was assigned
- o the. testing laboratory on a full-time basis.
s
-( -
U.S. Testing personnel stated that erroneous tect locations were a chronic-problem regarding the 3echtel placed fill. The location of a :est was usually given at the time of the test by a labor fore =an or a laborer if the foreman wasn't :here. Secetimes, however, a foreman was not familiar wi;h the area in which he was working and the locatien was not provided-until sometime after :he test. It became necessary on occasion to withhold test results as a means of getting the test loca:icn.
Test eleva: ions were approximated sequentially.
The technicians further advised that rarely did a Bechtel QC inspec:er t requese a test. Screally, labor forecen regaes:ed themi Cn occasion a technician passing through an area would be asked by a foreman if a test should be taken. Upon completion of in-place tests, the results l were usually communicated :o the foreman direc:ing the work. Test I f ailures were also reported by telephone to QC or ?iald Engineering. A '
weekly reper: ef :est was provided :o 3ech:e1 OC and Field Engineering who reviewed anv :es: failures and resolved :her.
3
- 1. S. Testinc persennel advised tha : hey stere requested :o :ake'tes:s of cl2y fill while it was raining and in order :o do so, plus:ic was heldcover : hen to pre:ect their equipment while :he test was ?.ade.
Even : hough 1: was rainia;, the fill placemen: work was ac: 3:Opped an fh (w) - o-
! l
.i 0
( ('
(s_ i some' occasions. .A 3echtel foremac confirmed that density tests were on occasion taken while it_was raining. While this is not contrary to the specification instructions,'it is contrary to standard practice.
)
U. S. Testing personnel indicated that when moisture was added, the procedure,did not include blending the material which resulted in
' mushy seams. It is commonly accepted good parctice to disc tha fill s
after spraying it with water to add needed moisture. A Bechtel foreman-stated that if moisture was needed they compacted 6" then sprinkled it
~
and then added another 6".
Thel field engineer who was assigned responsibility for plant fill work 1
. stated he did not spend full time on soils work since he also had l responsibility .for two s tructures, the steam tunnel and general yard work. He,said he tried,to get out to the area where fill work was being done once a day. S<me times he did.and sometimes he did not.
He indicated it was his impression that the QC Inspector responsible for the' soils work en the day.snift visited those work areas'ence or twice a week. He confirmed that only oral instructions were furnished !
to the foremen whom he felt were conscientious. The main problem he experienced with the foreman was maintaining proper lift thickness.
The QC inspector who was primarily responsible for the plant fill work is r.o longer employes by*Bechtel. The QC inspea.cor who'was responsible
/'~'j for the plant; fill work on the night shift sca:ed that he tried to devote l about one-hour a night to the plant fill activities. He indicated that
( j d'. ring 1976-1977.thereLwas much emphasis being placed on cadwelding and rebar' work and it was necessary to spend the eajcrity of his time on those activities. He maintained that he did have fairly frequent-contacts vi:h the technicians who performed the in-place density tests, partic-ularly'when test' failures occurred. He indica:el 1: was his impression that the labor foremen were directing fill placement adequately.
Review of Inspection Procedures The following peccedures which are.rclative :o backfill operations i at >tidiand Cnits 1 and 2 between August 1971 through December 1977 l were reviewed.
- a. Sechtel lbster Project QC Instruction for Compac:ed Sackf.11 -
C-l.02 was issued for construe: ton Oc:ober IS, 1976, and it is presen:ly the :urrent instruction.which is used by Sechtel GC (when Bechtel is :he inspec:Lon agency, providing first level inspections during backfill opera ions). Further, this instruc-
- ion was used by 3echtel QC when monitoring :he activi:ies of I
4 V 3 -.
l l
l l
- l
. 1
!\ ( (
\s_ /
other inspection agencies (Canonie) when such agencies were performing the first level inspections of backfill opecstions during the time periods of October IS, 1976, until June 13. 1977.
- b. Bechtel Quality-Control Master Inspection plan for Plant Foundacion Excavation and Cooling Pond Dikes (Plant Area Backfill and Berm Backfill) - Procedure No. C-210-4 was the instruction utilized by Bechtel QC when monitoring the activities of other inspection agencies that were providing the first level inspeccions of back-fill operations (this instruction was utilized during time periods prior to October 18, 1976).
- c. Bechtel Quality Control >bster Inspection Plan for Structural
- Backfill Placement - No. C-211-1 is an instruction utilized by Bechtel QC when performing firse level inspection of backfill activities prior to October 18, 1976.
Eechtel Procedure C-l.02, listed above, was written as a replacement for both Procedures C-210-4 and C-211-1. The inspection ivities which were delineated in Procedures C-210-4 and C-2!1-1 . . conpared with those described in Procetate C-1.02. The following a.e some of those activities which were caapored:
Inspection Code for--
, ,- .y
./ 1 Activities / Task.Descriotion C-210-4 C-211-1 C-l.02 f f
'O Backfill Material
(*) 1. Free of brush, roo ts, sod, I S(V) snow, ice or frozen soil.
(*) 2. >bterial moisture conditioned S I S(V) to required moisture content.
- 3. Structural backfill used . I with 3" of plant structure, shall be cohesionless and ,
free-drainin2.
l
(*) 1 Material not placed upon I S(V) frozen surface, l' 5. Foundation epproved prior to R H R'H backfill placement.
- 6. Prior to start of work, area I(V) free of debris, trash and unsuitable material.
[3 0 i
, \ , _,/ , i
t , . <
t s /.
(
' \J .
Compaction Recuirements
- 1. Cohesionless material com- 5 S S(V) pacted not less than 80 relative density.
(*) 2. Cohesive material compacted W S S(V) to not less than 95% max, density.
(*) 3. Zones 1, IA, 2 and 3 material W I S(V) in uncompacted lifts not ex-ceeding 12"; areas not access-ible to. roller equipment the material placed in uncompacted lifts no exceeding 4".
Material Testing
- 1. Verify testing and test results are as per engineering requirements.
- a. Materials S S S(V)
/
\
).
- b. Moisture 5 S S(V)
%J . o Compaction S(V)
- c. 5 S
- 2. Review lab test report verifying:
- a. Proper test method. R R R r
- b. Proper test frequency. R R R
- c. Technical adequacy. . R R R I - Inspection point R - Hold point W - Uitness point S - Surveillance (V) - visual R - Review records Those activities identified by an (*) asterisk indicate inspection require-mants which have been relaxed from the cricinal procedural requirements.
It is considered that the relaxation of actions relating to the ecnfir-mation that soils placement activities were conducted according to A
a _ 2s .
vf 1
v .-~~. m ,
/
sf .
. l >s specifications c- :ributed to icadequate compaction of foundation and fill material and increase incidence of deviations from specifications regarding-lift thickness, moisture control and frequency of testing.
This failure to provide adequate inspection of activities affecting quality is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion X. (3 9/76-20-10; 330/70-20-10)
Exit Meetings Members of the NRC staff met with Consumers Power Company and 3echtel Corporation at the NRC Region III of fice on February 23, 1979'to present the -scope, purpose, and preliminary findings of the investigation. Thar meeting was subsequently followed by a second meeting held on March 5, 1979, during which consumers Power Company responded to the preliminary investigation findings. The documents used during these meetings were transmitted to Consumers Power Company by MRC letter dated March 15, 1979. e 1
t
, : e .
_,b l
l .
1 1
,/'~'s
, e
~ s_s! , ;g .
ATTACHMENT 8 O
C ( i
\
s APR 9 - 1979
. . , I: \
A7ehet lio-Cccket No. 50-330 l l
Consucers Power Company ATT:Ir Yr. Stephen 5. IIonell
-Vien President 1945 k'est Parnall Road Jackson, MI 49201 1 Contienen:
l This refers to the incoection conducted by Mr. E. J. Calls;:her of i chis office on March 23-29, 1970, of activitics at the Midland Eucicar Plant Units 1 and 2, a'uthori::ed by N?.C Construction l Persits :o. CPPR-81 and To. C?PR-82 and to the diccussion of our j findin;;s with !?essrs. D. Miller and R. '.'o11ney and others of your staff at the conclusion of the inspection. i
?U- I) 'The enclosed. copy of our inspection report identifies areas
(
. exanined during the inspection. The inspection consisted of l
. an e:utnination of the continuing exploratory soil. Sorints progrsm and settic=cce monitoring of. plant cres fill.
No items of noncocpliance with :*RC reauircecnts tcre identified ;
during the course of this inspection.
, In accordance with Section 2. 700 of the SEC's " Rules of Practice," Part 2, Title 10, Code of Federal Per,ulations, a copy of this letter and the onclosed insometion report trill be placed in the NRC's Public roc' cent Room, except as follows, if this report contains information that you or your contractors l believe to be proprietary, you must appiv in vriting to this j office, vichin eventy days of vour roccipe of this letter, to ;
vichhold such information from public disclosure. The application must includo a full statenant of the rennerr for which the infor=ation is considered treorietary, and st 7uld be ;
prepared co that proprietary infor=ation identified in the application is contained in an enclosure to the application.
t kv) i.
1)vtE of 1 790594'OTM L
g . . . . . .s ,
- ..s ,a - + .- r - am.,
4
)
. . l l
\
l i
( (
' l t
7 ; consumers Power Comparcy - 2- APR 9 - 1979 l
J 4 -
- We vill gladly discuss any questions ycu have concerning this inspection.
J:
t j' Sincerely,
' 4 1.
+
Caston Fiore111, Chief Reactor Construction and Engineering Support Branch
Enclosure:
, ' II 1- ,. _ a - *
'.' Reports !!o. 50 ..,/79-06 l and :To. 50-330/79-06
. .l .
1 cc w/cnc1:
. Central Files L Reproduction Unit tiRC 20b PDR p Local ?3R
\'v.. !! SIC .
. TIC Ronald Callen, !!ichigen Public ,
i Service Cornission I ! Dr. Wayno E. North !
Pyron !!. Cherry
.s l'
1 ,
l.
l:
- j. RIII RIII RIII RIII RIII
. Gallagher/bik :Iayes. Fior:111 Cook Hansen je
. ,p. 4/3/79 l
. . - . .: .:- . . -., ._.-.-....--..a-..-..-_...--._.__-._.-..-_.-:
\
, [ [ :
. . 1 4
V ,
U.S. NUCL' EAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND DiFORCEMENT l l
I REGION III Report No. 50-329/79-06; 50-330/79-06 Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2
. Inspection'At: Midland Site, Midland', Michigan Inspection C,onducted: March 28-29, 1979 +
Inspector:
79.8m/q E. J Gallagher
- //{/'77 .
79pauA l
. {]j [ Approved By':
D. W. Hayes, Chior E ngineering Support Section 1 f/9[7f Insoection Sum =arv Insoection on March 28-29, 1979 (Recort No. 30-329/79-06: 50-330/79-06)
Areas Inspected: Followup 10 CFR 50.55(e) report concerning settlement of diesel generator building and. plant area fill; monitoring of settle-ment, piezometer, strain gage and pipe profile survey measurements; soil l ' borings in plant area fill and beneath safety-related structures. The
! ' inspection involved a total.of 15 inspection hours by one NRC inspector.
Results: No items of noncompliance or deviations were identified in '
the areas inspected.
L
.n
. t (U
% %* OF 196QV073Y
. i. ,
[.
1 j
. i
,r-~ l l
1'. . ' ' ;
I DETAILS Persons Contacted.
Princioal Licensee Emolovees (CPCo)
- D. Miller . Site Project Manager
- D.~ Horn, Quality Assurance Group Supervisor 4
- R. Wollney. Quality Assurance Engineer,
- B. Peck, Construction Supervisor U..S. Testing Laboratory-J. Speltz, Lab Manager Bechtel ' Associates Professienal Coreoration
~
- A.' Boos, Project Field Engineer
- A. Ozeroff, Quality Assurance Engineer
- W.'L. Barclay, Project Field Quality. Control Engineer 1
a J. Wanzeck,.Ceotech Engineer, Ann Arbor Office.
.F. Wall, Geologist, Caithesburg Office
~
I L eN W.' Kinzer, Geotech, Ann Arbor Of fice
- I I D. Jinnett,' Quality Control, San Fransico Office
\_ / J. Hartman, Project Engineering, Ann Arbor Of fice i NRC Resident Insoector
- R. Cook i i
- r.
- Denotes those present at exit meeting Functional or Program Areas'Inseected Followuo of Reoortable Occurrence (10 CTR 50.55(e)) - Settlement of Plant Area Fill and Structures ,
l The purpose of this inspection was to observe the exploratory soil boring program which Consumers Power Company has undertaken in an effort to identify subsurface conditions of the plant area fill and 'sofl cendition beneath safety related. structures founded on
' plant fill. In addition,'a review of the current soil boring' logs, l settlement data compiled for structures and piping.and monitoring of ground water levels was perfor:ed. Future planned activities were also discussed with licensee personnel.
1 L N_/s 1 o
I 1
l l
, , _ _ , . . . . - - . . . ~ . . . _ . - . . . . . - . , , , . . , . - . ., --. . - , ~ . . - ~ . , , , , , - -
y.
M
(
- 1. Status of Diesel Generator Building' Sectie=ent
.s
. The program of applying a surcharge of sand =acerial in and around
?n' the building has continued. As of March- 28, 1979, approxi=ately 15 feet of material has been placed and is proposed to be continued until a.cotal of-20_ feet of surcharge is in place. This surcharge
. is an attempt to accelerate any future settlement of DC Buidling by consolidating the foundation =aterial. The following are the total settlement measurements as of March 22, 1979:
DC Building Settlement:
North Wall - RE:SK-62BRC (Westside) 2.6" (Eastside) 4.1" South Wall - RE:SK-629RC (Westside) 4,25" (Eastside) 5.7" East _ Wall -
RE:SK-629RC. (Southside) 5.7" (Northside) 4.1" West Wall -
RE:SK-628RC- (3outhside) 4.25" (Northside) 2.6" DC Pedestal No. 4 Northwest Corner - 4.S" SK-65&P.A Northeast Ccener - 5.5" SK-635R3 Southwest Corner - 4,35" SK-625R3 Southeast C.tener - 4.3" SK-634RA j'~'s '
- c. n
- 2. Soil Borings in Progress
\' '
Exploratory soil boring operations are in progress in order to identify and develop the quality of =aterial in the plant area fill and beneath safety related structures. Soil borings are being taken in'accordance with the following ASTM standard =ethods:
- a. ASTM D-1586 Penetration Test and Splic Barrel Sampling of Soils. .>
- b. ASIM D-1652 Soil Investigation and Sa=pling by Auger Borings.
- c. ASTM D-1587 Thin Wall Tube Sa:pling of Soils.
The following recent preliminary soil boring logs were reviewed:
Soil Boring Building ID Location Co==ents i
RW-5 Radvaste Soft Material Elev 629-624 2, 2, 3 Slows /ft.
Aj'
(' [
'h ,,
(
1
~\s_,/I
- l l
DT-6 Diesel Tuel Lov Blow Counts Elev 620-613 l Oil Storage '3, 3, 8 Blovs/ft. '
I AX-4 Auxiliary Building Soft Material Elev 601 l 3 Blovs/ft. I AX-5 -Y ' Auxiliary Building Soft Materisi Elev 601/597
. 3, 4 Blows /fc.
AX-7 Auxiliary Building Loose' Material Elev 607-603 7, 2 Blovs/ft Soft Material Elev 603-595 5, 2, 4 Blevs/ft.
AX-11 ' Auxiliary Building' Soft Material Elev 616-606 3,. 4. 4, 6 Blows /fc.
S W- 4 Service Water Soft Material Elev 611-605 Intake 3, 2 Blovs/ft.
SW-5 . Service Water Low Blow Counts Elev 624-620
< Intake 6, 3, 6 Blovs/fc.
.j ~'s SW-5A. Service Water Loose Material Elev 628-618
.f I'
, Intake 5,~3, 8 Blows /ft.
\- / . .
SW-6 Service Water -
Loose Mater.ial Elev 601-599 Intake ,
SW-8 Service Water. Soft Material Elev 616-612 !
Intake Drill Rod sunk under own weight
- OL-4 Oily Waste Low Slow Count Elev 619-614 L 9, 7, 6 Blevs/fc.
Observed drilling in progress and split spoon soil sa=pling NOTE: (1) Blows per foot are deter =ined by the weight of a 140 pound ha==er dropping 30 inches in accordance vich ASTM standards.
(2) The ter=." Loose" refers to sand material and "Sof t" refers to clay =aterial, t
- 4.
. s~~ .
f A f' 1
1' t-I.
l r.
v . . , - , - , ~, . , . . , , . . _ , u. . . . - . . . . ~ . _ , . . . . . _ - . _ - - . , . . - . . -- ..
I i
l
(
,f m t -
N In addition to the above soil boring log's the following records !
of soil borings indicated relatively higher blev counts per foot:
AX- 1, AX- 2 , AX- 6 , AX- 8 S W- 3 , SW- 6 , SW- 7 , SW- 9 . The quality of the soil in these areas are presumed to be adequate.
A number of additional soil borings are still in progress in order to. develop a full profile of the quality of the focadation material.
- 3. Ground Water Levels in Plant Area Fill The cooling pond water elevation is now at maximum elevation 627. feet. Piezometers have been installed throughout the plant area in order to measure ground water elevations and the effect on settiaments. The piezometers indicated the following ground water elevations in the plant:
Location Water Level (feet)
Service Water Building SW-1, SW-4 SW-6, SW-7, and SW-8 626 Auxiliary Bu11 dies AX-1 AX-2 624
-Diesel Tuel Oil Ta'nks DF-6 627 l '/~~q _
lf-'
- Chlorination Building CL-1 -
626 Administration Building A-1. 624 Tank Farm Area T-19 615' Ground water elevations are continuing to be monitored in the plant' fill.
l 4 Profiles of Underground Picing Survey profiles of the ' service water lines in the plant fill have l been developed. This infor=ation is under evalurtion by Bechtel l stress analysis group to determine the stress induced due to l differential secclement of the pipe lines. The current plans l of the licensee are to take soil boring along the service water i and borated water lines in order to predict future settlements
- and perform an evaluation in order to determine whether the
( -
additional ~ stress levels are vichin the permissible ASMI Code requirements. No infor=ation regarding the evaluation was
, available at this ti=e.
1 l'
r- -
l l.
1 L
_.._.2 . _. .. . . _ , . . . _ _
4
(~ :(
4 *
/~ N ,
\
' !' l
%/
- 5. Crack Maoping and Strain Gage Measuremen:s Field survey's of existing cracks in the diesel generator build-ing and service water intake structure have been performed.
Strain gage measurement devices have been installed on the diesel generator building to monitor the displacements of these cracks due to the effects of the surcharge being applied to the building foundation and walls. No plans have been made to install strain gages on the. service water structure, however, periodic visual observations are made to determine if any additional cracks occur and the width measurements of these cracks. Crack vidth measure-ments continue to be monitored as well on the DG Suilding using the strain gage instrumentation.
6.- CPCo Investigation of Possible Causes of the Plant Area Fill i S e t tlemen t CPCo and Bechtel have developed the following preliminary list of possible causes which either individually or collectively contri-buted to the settlement failure of the diesel generator building and plant area fill material,
- a. Placement met. hod regarding lift thickness, moisture control, compaction equipment and type of materials.
.p)
\-~'
- b. Theoretical comparison between Sechtel Modified Proctor (AMP)
Compaction test versus secclement.
- c. Specification C-211 regarding the omission of frost protection and flooding of trenches.
- d. Testing of plant area fill.
- e. Test frequency and location for scall areas,
- f. Work performed by dif f erent contractors regarding personnel qualifications and inpsection methods.
- g. Extensively re-excavated areas regarding procedures and control.
- h. Filling of the cooling water pond in March 1973.
- 1. Moisture intrusion in ground compared with compaction.
- j. Stockpiling material relative to moisture control (veathered, drying out).
b u
I (
i A \
, ,)
- k. . Investigation of moisture control (dry year in 1977). ,
I
- 1. Inspection procedures af ter March,1977. j m.. Personnel Qualifications .of Bech;;el, U. S. kesting and Connoie contractors. V l
Details of the licensee's ef fort in this area vill be reviewed when completed.
- 7. Planned Activities The licensee is planning to perform the following activities to identify the quality of subsurface materials:
- a. Perform lift thickness test to verify if the required density could be achieved using hand held compaccion equipment with a ,
maximum of 12 inch lifts.
- b. Excavate test pits in order to visually observe the subsurface
- materials and pe'rform in-place density tests : co compare with cuality control records. ,
- c. Continue preload in DG Builidng by applying a surcharge of 20 feet of sand to accelerate consolidation of foundation
~
,/,
l.
I
( .
=aterials.
- d. . Study alternatives for additional support of the service water
- intake structure and portions of Auxiliary Building. (
- e. .
Perform pipe stress analysis on piping in the plant fill such.
as servjce water lines and condensate 11res,
- f. Continue to perform soil borings as identified on drawing C-1145 R2 to identifyisubsurface conditions in the plant fill.
! Exit Interview The inspector met with site staff representatives (denoted in Persons Contacted) at the conclusion of the inspection on March 29, 1979. The inspector summarized the purpose and scope of the inspection. The licensee acknowledged the findings reported herein. The inspector re-quested that the licensee provide a weekly status report by telephone communic. scions in order to keep the N?.C ?,III office apprised of the s tatus' of the site exploratory program. The licensee acknowledged this request vould be acccc:modated. .
p av L-i L'
s g g g ou 9w e yre v g y 9 -uww + g u 4 es p we 4-vi* w'ai-t- er m:
g ATTACHMENT 9'
.6','
Question 1 - ,
Your quality ' assurance (CA) program, which falls under the provisions of 10 CFR 50, Appendix 3, was applicable to the technical information that went into the PSAR and FSAR and the design and construction of the diesel generator build-ing. In our view, the unusual settlement problem at the site points to an apparent lack of implementation of c'ertain QA program requirements. Therefore, provide the following (a) Identify those quality assurance deficiencies that contributed to this problem, the possibilities of
.)' these deficiencies being of a generic nature and affecting other areas of the facility, and describe the corrective actions you have taken to preclude *~
these deficiencies from happening in the future.
(b) What assurance exists that the apparent areas of contradictions in the PSAR and FSAR as described by ISE during the meetings of February 23 and March 5, 1979, do not exist in other sections of the PSAR and FSAR dealing with matters other than fill?
(c) Inves'tigate. other activities not associated with the fill, but important to safety for other systems, components, 'and structures of the Midland f acility to determine if quality assurance deficiencies exist in view of the apparent breakdown of certain
- quality assurance controls. Identify those items ^
investigated and the results of your investigation. ,
(d) Considering the results of your investigation on Item (c) above, describe your position as to the overall effectiveness of your QA program for the design and construction of the Midland Plant. i Resconse'htoQuestion1,Parta)
Appendix I provides the quality assurance deficiencies.
Each item included in Appendix I has been classified as a deficiency for the purpose of assuring that each item is addressed for generic implications.- The items may be Items of Nonccmpliance identified by the NRC, deficiencies idencified by Bechtel or CPCo, or conditions which have not been ruled
- out as possibly contributing to the diesel generator building settlement problem. Appendix I also provides:
, 1. A detailed discussion of each deficiency, including its scope and possible' generic implications 1-1 V .
4
- O h e
,, , , , _ , . - , . . . . . - - . . . . - . _ - .,-._. - . _ m. ..-.m.._... , . . . _ . . . . . . . . . . - _ , _ - . . . . , ~ . ~ . . . _ . , _ , . . _ . ,
< l w l l
- I I 2.
The corrective actions taken to correct each deficiency s associated with the sectiement. problem
- 3. If the deficiency. has. generic implications, actions taken to preclude recurrence of the same or similar deficiency Rosconse (to Cuestion 1, Part b)
The. Midland Final Safety Analysis Report (FSAR) was prepared in accordance with Sechtel's ,Ingineering . Department Procedure
] ' (EDP) - 4. 22, Preparation and Control. cf Safety Analyses Reports. The Bechtel-originated FSAR sections were written i
based upon information, requirements, criteria, and commitments ," '
contained in the various' documents identified in the Midland
, Proj ect FSAR Section References . form (Attachment 1-1) .
^ These sections, as well as chose originated by CPCo or asW, -
1+are distributed for internal Bechtel interface coordination with review by project discipline groups, off-proj ect support groups, and .the discipline chief engineers. Documentation of this coordination and resolution of comments were maintained by the use of three additional for:s: Midland Project FSAR Interface Routing Slip (Attachment 1-2) , Midland Proj ect FSAR Interf ace Comment Closurm (Attachment 1-3) , and Midland I
A J
P'lant FSAR Chisf Engineer's Comment C1cause . (Attachment 1-4) .
Finally, the individual FSAR sections were distributed j' h to CPCo and.B&W and a three-company meeting was held.to 3 i
reviav and approve the final sections. The purpose of this everall procedure was to ensure that all appropriate licensing and project design documents were considered when preparing the FSAR sections and that, appropriate interf ace coordination
-was conducted.
The 'Mid1'and -FSAR was submitted to the NRC at an earlier point in the project schedule than wculd have nork ally occurred.in order to provide additional time for una operating license hearings due to the forecasted intervention. Conse-quantly, . some of the material required to be included in the
, . FSAR was not available at the time of its initial submittal, or was supplied based upon preliminary design informatien.
, Am the design and construction continued, the appropriate sections of the FSAR were revised or updated tc include the ~
necessary information.
In addition, 973 official NRC questions were issued on the Midland docket (850 on the FSAR and 123 on the environmental
, report). Several of these questions resulted in design ch anges . - As these changes were made, the apprcpriate sections of the FSAR were revised. An audit of 3echtel Project
-s Engineering 'was conducted by 3echtel Quality Assurance en _
s*
1-2
..ns
- ...._.
- . , .. ... .--.. -. . - - - - - - - - - ' ~~~~~ ' ~
4
=, s . * .
( January 22 through 20' 1979, to ensure that there is a 4
system by which design changes are reflected in' the FSAR and that this system is properly implemented.. In addition, there were numerous-CPCo QA audits which included this aspect, To identify and track missing information in the FSAR, an Amendment / commitment List was created. This list gives the appropriate FSAR section reference, a brief description of the missing information and the action required to resolve the open item, the due date for closure, and the responsible '
i, , organization. An example of the Amendment / Commitment List !
- ' is included as Attachment 1-5. '
Through the ab'ove procedures and actions, the FSAR and - ,e-project design documents are constantly being reviewed and
, compared against each-other. When inconsistencies are identified, they are corrected. However, there are some sections of the FSAR that are essentially inactive (e.g. ,
the FSAR section relates to items for which the design, ,
procurement, and construction phases have been completed and there have been no recent document changes or NRC questions to prompt a review of the section).
Prior to the identification and investigation of the diesel 4
. generator building sectiement starting in August 1978, ?SAR Section 2.5 and Subsection 3.8.5 (which were the. areas of
, contradictions in the PSAR and FSAR as described by'ISE.
, \ during the meetings of February 23 and March 5, 1979) were .
, considered inactive. All of the major plant backfill opera- ^
i tiens were completed, no significant revisions to the related civil specifications or calculations were made, and only two NRC questions were received at that
- e. These two NRC -
questions were related-to Section 2.5 and dealt itith the seismicity of the Michigan region.
Although the above activities have been and are now being
- implemented, it has been decided that in order to provide assurance that areas of contradiction do not exist in other t
' - sections of the PSAR and FSAR dealing with matters other than fill, the following additional actions will be taken. *
. 1. A PSAR Commitment List was created in 1973 to identify and track design commitments made in the PSAR and related' licensing documents. A sample sheet f::m this list is included as Attachmee's 1-6. Several revisions of this list were issued to update the " status" and
" disposition document" columns. This list was also used in developing FSAR Table 1.3-2, Significan Design
}' Changes, which identifies the significant changes made )
since issuance of the construction permit. To assure '
[ that' the PSAR design ec:::mitments were p cperly dispo-sitioned tArough incorporation into a p cject design a pO
! v.
v
. z.2
. l ... _ . _ ,_ _ _ . _ . _ - . _ . - . . . _ . . . . _ . _ . ~ _ _ _ _ _ - _ _ _ _ _
. . ..., ; .. _ - - _...... .- - - -- - - - - '~
s . '
)
document or the FSAR, a- final review and update of the PSAR Ccamitment List will be completed 1by January li 1930, [1 2.-
To assure that no areas of contradiction exist between the FSAR, PSAR, and project design documents, a review of sections of the FSAR that are determined to be inactive will be completed by January 1 1980. For this purpose, an iu ctive FSAR section is defined as l1 i
- any section for which the basic technical content has 1 not changed since the initia1' preparation of the FSAR J ', .and for which there.are no outstanding unanswered NRC questicas or identified. Safety Evaluation Report open.
items. Any inconsistencies identified during these 's" review activities will be resolved and all appropriate changes will be made to the FSAR. A review of the remaining sections of the FSAR is not considered necessary because of the ongoing review process described above.
- 3. EUP 4.22, Preparation and Control of Safety Analysis Reports, provides a system for' controlling the preparation and revision of safety analysis reports. This procedure will be reviewed by June 29, 1979, although there are no apparent needed improvements noted at this time.
L4 l
- A .Qua'11ty Assurance audit will be made of the three p
actions noted above.
iA q Reseonse - (to Question 1, Part cI
'w The previous dis'cussions describe known quality -assurance -
! deficiencies relating to the diesel generator building settle-ment, corrective actions taken with regard to the deficiencies .
as they apply to the settlement problem, and actions taken. for the deficiencies as they apply generally.
In addition' to these specific actions previously noted, other s
actions related to the generic nature of the deficiencies identi .
fled' have been taken or are in progress. These resulted frem CFCo
- and Bechtel's Laplementation of their QA programs. A brief
. description of these actions follows.
- 1. A review was completed by Bechtel Quality Assurance in January 1978 of the use of the Field Change Request and L
Field Change Notice to obtain clarifications of specifi '
l .
cations and drawings. This review concluded that there is an awareness of the need for specificity in specifi-r cation and drawing preparation on the Midland project.
'2 . A review of specifications covering items such as
' references, tolerances, and clarity of the specifications l
was undertaken by Bechtel and CPCo in late 1977. This 1
,<~q 4
'jN- l '
Revision 1
, 1-4 5/79 l'
-s
^M.J
' Q8 ., . . . . ' . ~ . . . _ , . - . - . . . . . - . . . .
. . . . . _ . . . _ ~ . , . . . _ - - . . . . _ . , . , . - . . , _ . - - - _ _ - . ~ . - . _ _ . _ . . . . . _ , -
~
- ., .'.. . . . _ _ . . . - - . . . ~ . - - -- - - - - * '
t a .
\ .
... I
- l study.resulted in revision of several specifications.
Most of the specifications used.by construction were
' included, but the soils and . concrete specifications . ,
I werenearing
. was not used because the scatus of this construction completion. ;
A review will be undertaken and completed by June 29,1979, of specifications not ,
included in the initial study, but still' in use in the field.
l This review will cover the same ' areas . as the
, original scudy. Specifications C-210 and C-211 have ~
been the subject of review subsequent to the discovery I of the settlement problem, and have been revised to '
'* provide a better definition of the requirements.
s
~l- 3. ,
During the specification. review, Bechtel Quality Control and C7Co QA also reviewed each active Quality =~
' of Control Instruction (QCI) in use to ensure the callout-adequate inspection criteria. Where additional clarification of specifiestions was considered necessary,
- this information was forwarded to Bechtel Project Engineering for resolution and included in the study
' discussed previously.
4
- During September 1977, Sechtel QA revised their monitoring program to provide for more in-depth verification of QA
,. program requirements. At the same time, Bechtel CA management audits were increased from one to two per year. dechtel' QA. engineers assigned to the site have.
- been increased f cm five in 1977 to a present level of t-((s -hj eight. '-
e -
- 5. In 1976, CPCo QA instituted a program of overin,spection of certain-Q-listed construction activities. To implement this program, C7Co QA personnel at the site were increased from 5 to an. average of 20 over the period from 1976 to 1978 to support new activities (mechanical, electrical, i
etc) being started.- C7Co QA personnel in the Jackson I office were increased f cm one to six (excluding the Audit and Administration Section) .
-a. Areas that were subject to overinspection included . 1 the follcwings (1) Reinforcing steel installation - initiated in June 1976 on a ~ sampling basis, and La Cctober, 1976, for 100% review (a) 1976 - 53 inspections -
a (b) 1977 - 306 inspections 4 (c) 1978 - 145 inspections L
4hs ue ,
1-5 e
'r #
l b.. A.I -
1
, _ . ._. __. .. . -- -- - , .- i
, . 1
< , i
- e. . l
.(
, (2). Structural em~ bed =ent installation - 1005 (initiated during June 1977)
I c
, (a) 1977 - 168 inspections
, (b) 1978'- 84 inspections (3) vender x-ray Laterpretation .' initiated in late 1978 and presently 100% review for -
radiographs received (4) Field radiograph interpretation - sample-J'
- basis started concurrent with the start of radiography
'e~
- b. Other areas subject.to a total increase in audits and overinspections included,1but were not limited tot u
(1) Mechanical activities (2) Electrical activities ,
overinspections in these areas total 101 for the last.6 months of 1978.
c.
Audits conducted in all areas by C?co site QA' personnel are as followc:
- l- ' .
l .s (1) 1976 - 76 audits *
(2) 1977 - 48' audits (3) 1978 - 51 audits 6.. Resident engineers have been assigned at the site to i aid construction in the proper interpretation of draw- ;
'; . ings and specifications,- aid in the resolu icn of problems such as intarfarences, and provide clear direction of the specification intent. These' residents -
have been increased in number from 1 in March 1976, to the current figure of 22.
7.- In April 1978, Bechtel QA initiated supplementary L. guidelines to indicate certain c:iteria for initiating tracking charts to aid in identifying trands in any L particular area for repetitive occurrences. These charts are issued monthly to C7Co and aechtel CA ' manage-ment.
\
The composite effect of these actions is to p. ovide increased I '
assurance of program compliance in all areas.
/]
(V -
1-6 9 .
'h 'N
I
! e t
.s.
Re'seense (to_Ouestion 1, Part d) .
( The preceding discussions describe various diserapancies l discovered as a result of the settlement investigation, 4
co.rrective actions associated with the soils activity,-ar.d w {
corrective actions planned or takan.in other areas to rasure i that these deficiencias do not. exist and are precluded else-where.
i j
This discussion also describes reviews and correc-tive actions which were taken prior to the advent of the settlement problem, but which continue' to apply generically. i i
It is emphasi::ed thit the sett1=ent monitoring program (by which the settlement proolem was initially detected) was an -
} integral and Assu:ance Program. continuing part of the overall Midland Quality It is CPco's position that the Midland Quality Assurance P=cgram being implemented on the Midland Project is effective. ,
1
.h i
l . .
l l ,
e 4
1 e
i .
1
. 1-7 l
l l .
. . - - - - , . . . ~ . _. . - . . , , . . . . , . . . _ - . , - . . . _ . . . _ . . . _ . _ _ _ _ . . _ . . , . _ . _ . . . _ . . . . . . . _ . . _ _ . - - - . . . . _ . . . . _ - , _ . _
af ,
..?
Appendix I
'u
- I CATEGOR'l I DESIGN ACTIVITIES A. Deficiency
Description:
- 1. Inconsistency Between Specifications And The L Dames & Moore Report ,
A number of consultant reports have been added as appendixes to the PSAR.
1-'. : numerous and sometimes conflicting These reports contain recommendations. These reports are subject to be y-construed as commitments. For example, the. Dames
& Moore Report (referenced.as an attachment to the PSAR in Amendment 3 to the PSAR) makes certain recommendations relating to the compaction and protection of soils. Certain of these recommendations were not specifically called out as requiramants in the implementing specification.
- 2. -Lack of Formal Revisions of Specifications To Reflect Clarification of Specification Requi,rements
[ ,
' Conflicts existed between Sections 13.7 and 12.4 of Specification C-210 relating to the laboratory
. standard to be ;used. . These paragraphs were the 4
subject of-clarification communications.
- a. Specification C-210, Revisions 2 through 4,
.Section 13.7 originally required cohesive ;
soils to be compacted to not less than 95% of
. . . modified proctor method (ASTM 1557, Method D) . "
q
'" ~
, b. Specification C-210, Revisions 5 and 6, Section 13.7.1, Cohesive soils, states, "All cohesive backfill in the plant area and the i berm shall be compacted to not less than 95 percent of maximum da.nsity as determined by ASTM D 1557, Method 0."
- c. Specification C-210, Revisions 2 through 6, 1
Section 13.3, Testing, states, " Testing of.
all materials placed in the plant area and the berm will be performed in accordance with the tests listed in Section 12.4" f d.
Specification C-210, Revisions 2 through 6, section 12.4.5.1, Cohesive Soils, stacas:
"The maximum dry density and optimum =oiscure I-1
.....,....._'.',,,..,....,_.~,._.,...___,.~.....,.._.....,.......,.....,__..,._._.__..___._,.m..__ _ - _ _ . . .
i I
,_ . . . . . . . . . . . . * ' ~ ~ '~
~' .
1 content of cohesive material will be determined in the laboratory in accordanen '
with ASTM Designation 0 1557, Method 0, provided that the sample is prepared in 4 layers, each compacted with 25 blows with a 10 pound hammer dropping 18 inches giving a )
compactive per cubic foot.
energy equal to 20,000 foot-pounds i Density test) . "
(Bechtel modified Proctor .
l
'[- 3. Inconsistency of Information Within The FSAR Relating To Diesel Generator Building Fill Material And Settlement 'ri The FSAR submitted to the NRC (through Amendment 17) contained certain inconsistencies:
- a. Tables 2. 5-9 and 2.5-14 identify the foundations under the diesel ganarator building to be cohesive fill. The actual material specified and used was random fill, L - which includes cohesive and cohesionless material and concrete.
" . b. FSAR Subsaction 3.8.5.S indicates a
- settlement of 1/2 inch for shallow spread
- footings (such as the diesel generator building), - FSAR Table 2. 5-48 indicates a ^
settlement of the diesel generator building '
of approximately 3 inches.
- 4. Inconsistency Between Basis For Settlement Calculations For Diesel Generator Building And
- Design Basis
- a. ~ Settlement calculations for the diesel generater building differ from the design requirements in the following ways:
(1) A uniform load of 3,000 psf was used rather - than the 4,000 psf shown in Figure 2. 5-47 in the TSAR.
' (2) An index of .001 was used rather than the index of .003 shown in Table 2.5-16 in the FSAR.
(3) The calculations assumed a mat foundation rather than a spread footing foundation, which is the actual design condition. 3 l
k
=. ;
l I-2 l
4 r.
9
l
- - _ , ... . . ~
p,
- c. . -
j
~ '
h 4...
S s, b.
The results of these erroneous calculations were included in the FSAR.
5.'
Inadequate the Duct Bank Design Coordination in the Design of
' l l
Four vertical duct banks were designed and i
l constructed without sufficient clearance-to allow a
and relativa vertical movement the building, and therefore' between the duct restricted thebank
- settlement of the diesel generator building.
B.
Discussion Implications:
of The Deficiency,.Its Scope, And Generic ' arf (The numbers below correspond to the numbers under Part A above.) 1 i
' 1. Project engineering specifications meet the t
commitment for compaction of soil as stated in PSAR Amendment 3, dated August 13, 1969. PSAR Subsection 2.8.4.1 states, "All fill and backfill materials are adequately compacted to insure stability of _ the fill and to provide adequate support for structures founded on this fill without excessive settlement." Specifications C-210 and C-211 provide sufficient criteria by which to ensure that the fill is adequately placed t0
, ) ,
,prevent excessive settlement.
' ,3 As stated in PSAR Subsection 2. 8.1, Introduction, "This section presents the summarized results of studies of the foundation investigation phase. . . . "
Although the Dames $ ~ Moore report is referenced in this subsection, it was not intended to be a PSAR -
commitment except 'for those portions specifically indicated in the PSAR.
! Therefore, the. differences between the Dames &
. Moore. recommendations (or other consultant recom-mandations) an4 the specification requirements do not' indicate PSAR. a failure to meet commitments in the These recommendations were-considered by Sechtel Project Engineering and appropriate ones were requirementscommittedintothe in the PSAR and included as specifications.
i
- 2. Letters, TWXs, telecens, and memorandums are often used' to clarify the intent of the specifications,
- f. It is possible that in some situations the i clarification provided through the above methods i
- may have modified the specification without f ormally- changing the wording of the specifications.
t generic to other areas.
This is considered potentially fx_//
l 1
I-3
, _ . ..... . a' l l
1 a ?
t
- 3. ' Refer. to the response to. Question .1, Part b.
[ \ l
(,,/ 4.- The diesel generator building settlement ,
s calculations were based on preliminary information
. supplied by 3echtel Project Engineering in March 1976 which included a uniform loading of 3,000 psf over the entire building. The-calculations were checked'in the San Francisco office in March 1977. -The final design was released by Bechtel Project Engineering in March 1977. .
^
l~
A fill soil compressibility factor of .001 which was used in the original settlement calc';14 tion was later determined to be less appropr!. ate than e:
f actor of .003, and a f actor of .003 wau stated in the FSAR. The individual responsible for ths ~
' original calculation did not become aware of this change until after the diesel generator settlement problem surfaced. Thereafter, he determined that the change, in this case, would result in a predicted settlement that was insignificant 1y different from that predicted in the original calculation. This was not noted in the original calculation. .
Checking of the calculation was completed prior to completing the coordination of the final design (G
^- /
1 * .
configuration. The original calculations were based on a uniform load of 3,000 psf and a mat ^
foundation, whereas the final design was based on a uniform load of 4,000 psf and a spread footing foundation. The -originator of the calculation was aware of this change on a timely basis, but it was determined that because conservatism was used in the. calculations, the change in results using the final design parameters would be small and within the accuracy limits of the analysis. However,
, this was not noted in the calculation. - .
Although it is felt that this is an isolated case, to assure compliance with the requirements of EDP 4. 22, and EDP 4. 37, ref er to Part C (below) for a discussion of the cc::ective action.
- 5. Project design Drawings I-302 and C-1001, Revision 2 and C-1002, Revision 2 resulted in-a 1-inch separation gap being specified between the duct banks and the diesel' generator building foundacions to allow for differential settlement.
The applicable electrical drawings indicate
[
.(
N- ,
I-a
?
. -- - . , . . - . _ , - - ...., -~- - . - . ,,., - .
minimum dimensions only, and do not reflect as-built. dimensions. Therefore, the cogni: ant engineer went to the jobsite, measured tha exposed duct banks, and desicned the openings in the footings-accordingly. At the' time of this jobsite visit, the backfill and a mud mat covered the enlarged cross-sectional area of the duct banks n.
below the footings.. .From the information .
available to the engineer, .it was not apparent that the duct bank under the opening was larger l than the part proj ecting through the~ mud mat. ,
Coordination failed'to identify a second
)
r electrical drawing, Drawing E-42, Sheet 33, - .-
Revision 4, which shows that buried duct banks .
i j
have more concrete cover over the conduits in the duct above than thewasfootingrequiredlevel.for the exposed duct bcnk,
- As a result, the design did not specify a vertical gap between the bottom of the footings and the enlarged duct bank section. ,
coordination of drawings 'is accomplished in '
accordance with EDP 4.46. This procedure requires a coordination print to be utilized and signed by the affected discipline engineers. ,only the last I 1
- revision of the coordination print is required to be retained.. . ,
a i
Most interdisciplinahy , interfaces are self-evident as to interferences .that may arise from other design or construction. There are specific design bases for th< separation between seismic Category I systems, and between. Seismic Category I and non-Seismic Category I systems. Below grade interf aces are not easily accessible for later verification, whereas accessible interfaces will l-
. be subject to walkdown inspections at the completion of construction.
l This final check will verify compliance with separation criteria and the l absence of interferences.
Based en the above, we do not consider this case
.a to'be generic, but rather an ancmaly. This is supported by the fact that 3echtel Quality .
L Assurance and Quality Engineering have ecmpleted 16 monitors and audits in the area of design coordination over the last 16 months,'and have not identified any significant deficiencies.
e a -
I-5 ,
- y. ,
.s.*
,. , . , , .,.m.,, , , , , .- .~.e , 4-, 4 .w.~. _ . _ ,,,_..._.m..., ~ .. ._, ...___m... _.m._
l l
. 1
' [\ C.
\sl Actions Taken To Correct The Deficiency Associated With The Settlement Problems to the numbers under Parts A and 3 above. )(The numbers below corre) 1.a. Specifications C-210-and C-211 have been revised by issuance of Specification Change Notices (SCNs) i C-210-9001 (March 30, 1979) and C-211-9001 (April 2,1979), which provide for: "
(1)
Maximum density of cohesive soile using ASTM D 95%;
of 1557, Method D, with a minimum compaction
} .
(2) Moisture verification of adequacy to be at
"~
the time of field density testing; (3)
Maximum loose lift thickness of 8 inches for motorized equipment and 4 inches for hand-
. held equipment; (4)
Minimum ecmpaction of 85% relative density for cohesionless soils.
1.b. A complete review of the Dames & Moore Report will be completed and a documented disposition will be l (N made for any other apparent differences between
- the Report recommendations and the project
( ")
s specifications.
June 29, 19 79. -
This review will be completed by ..g 2.
Specifications C-210 and C-211 have been revised as previously stated in Section C.1.a above.
On April 3, 1979, the Midland Project Engineering Group Supervisors were reinstructed that the only procedurally correct methods of implementing specification changes are through the use of
. specification revisions or SCNs. This was reiterated in an IOM to the Group Supervisors from the Midland Project Engineer on April 11, 1979.
l_
- 3. Pertinent portions of FSAR Sections 2. 5 and 3.8 are being reviewed,'and FSAR change notices have been and may be written to correct the inconsis-tencies and presented. to add clarification to the material FSAR change notices were incorporated' into 1979).
the FSAR in Revision la (dated February 28, completed The by remainder June 29, 1979. of these reviews will be 4.a. Settlement calculations will be made again subsequent to the completion of the diesel generator building surcharge operation.
r . .
=4 .
I-6 y- # g w-t w y -- eg -* y e-e p $ e- e awy, rem--v-- ++,y e e g ,-y4-eyy->aymgww-emy7 wi e i h-
4 p)
N' 4.b. The importance of updating support documents (such as calculations) as new design information becemos available in order to avoid discrepancies has been reiterated by an internal memorandum to the Bechtel Geotech Design Team dated April 12, 1979.
4.c.-A recent sechtel Quality Assurance audit of the Bechtel 1979. Geotech Section was conducted in February, Although the results of this audit indicated that this area is effectively I- controlled, additional audits will be perfor=ed in this area on a 6-month cycle until completion of soils work. "~
5.a. Provisions were made to allow independent vertical movement the duct banks. between the diesel generator building and ;
5 5.b. Bechtel Project Engineering will review design drawings for cases wh'are ducts vertically through foundations. penetrate The possibility of the duct being enlarged over the design requirements and the effect this enlargement may have upon the structure's behavior will be e'vaP ed by June 1, 1979. Proper remedial
,e maa
(
as will be taken if the investigation shows potmaial problems. .
. x. ' .,3 D .'
Corrective Actions Taken To Preclude Recurrence Elsewhere:
1 (The numbers below correspond to the nu=bers under Parts A, B, and C above.)
- 1. Engineering Department Project Instruction (EDPI) 4.1.1 (issued in July 1974) provides a system requiring'that design criteria, contained in documents such as the PSAR or FSAR, be
- incorporated into the design. This requirement was previously found in the Sechtel Job Procedure l (7220) entitled, " Design Document Requirements !
Procedure."
- EDPI 4.1.1, Revision 0, Paragraph 3.1 states: "The Discipline Engineer who originates a design document shall fill out the attached Design Requirement Verification Checklisu (DRVCL) as he-develops the design document to assure that all l , applicable design criteria contained in each I referenced design doeurvnt document has been incorporated into the and to verify that no omission or conflict exist. If a particular Design Requirements Document is not applicable to the
/
/T/ design document, place 'N/A' in the space providad for identification."
gJ I-7 E.n- t
d b Exh4 Siti lLtc EDPI 4.1.1 includes a "pSAR/FSAR" N-
/ory and a "Sechtel discipline standards" C
category.
- To assure that this sys' tem is being implemented, Sechtel QA conducted an audit of this system on January 22 through 30, 1979. This audit resulted in two findings for which corrective actions are scheduled to be completed by May 18, 1979.
- ' 2.a. A' review of the ref erences, tolerances, and l
clarity of the specidications was undertaken by Bechtel and CPCo in late 1977. This study resulted in ap'propriate revisions to several =~
, specifications. Most of the specifications used for construction were included in this study, but the soils and concrete specifications were not because the status of this construction was nearing completion at that time.
1 2.b. Using the installation of the reactor building spray pump and ancillary system as a study mechanism, Sechtel and CPCo performed a dimensional tolerance study. The purpose of this study was to evaluate drawing and specification
,-, tolerances - and clarity. This study was concluded in early 1978, and preceded the majority of the .
-mechanical and electrical installations. The generic findings resulting from this study were '-
applied to other mechanical and electrical drawings and specifications, and they have been revised as needed.
' 2.c. A review of those specifications being used for remaining construction and not included in the studies described im Parts 2.a and 2.h above will be completed by June 29, 1979.
2.d. EDPI W.49.1/ Specification Change Notice, will be revised by May 1, 1979, to incorporate
' clarifications and instructions concerning use of specificatien change notices. ,
2.e. A specific review of the TSAR and specification requirements for the qualification of electrical and mechanical components has been made as part of the corrective action relating to CPCo's 50. 55 (e) report on component qualification.
- 3. Refer to the response to Question 1, Part b.
- 4. Calculational techniques and actual analysis will gr be audited to sa=ple the effectiveness of the t.
C .
1 I-8
.. a. . . - _ _ . _ _ . _ . . ~ . . _ . . _ . . _ , _ . . _ . . - . . . . - . _ . . _ . _ . . _ _ . . _ _ . _ . _ _ . . _ _ , _ _ - . -
1 design calculational process. Recent audits have been conducted of the ITT Grinnel hanger design and CPCc relay setting calculations. Bechtal will, on. a yearly basis, audit each of tiair design disciplines.
- 5. No further actions are required on this item.
9 a.
I e
0 6
O t 6
- 8 9 4
4
)
. g%
1
- I-9 :
I I
. . . ..c_ tir.1,... .
d ' ~. ,
[j ~
s/ CATEGORY II f
CONSTRUCTION ACTIVITIES A. . Deficiency.
Description:
i 1
1.-
Insufficient Compactive Effort Used In Backfill' operation
.. There are no records available to indicate.that -
/ the various types of compaction equipment used for structural thebackfill were evaluated orand cualified that to handle specified lift thicknesses =~
appropriate lift thicknesses were established for ;
each type of equipment.
2.
Insufficient Technical Direction In The Field The Dames & Moore Report and the Civil-Structural Design Criteria 7220-C-501, Revision 9, Section
' 6.1.1 sta te, in part, " Filling operations.shall be performed under? the technical supervision of a t
qualified soils. engineer...."
Technical direction and supervision were provided by Field Engineers and Superintendents who were assigned the responsibility for soils placement.
The direction and supervision were not sufficiently employed. -
3 S.
Discussion Implications:
of The Deficiency, Its Scope, And Generic (The numbers below correspond to the numbers under Part A above.)
1..
Areas of low density appear to be scstly confined to structural backfill placed in confined areas
- using vibratory type hand-operated equipment end in areas placed under Specification C-210 where equipment was not prequalified and acceptance was by test. l3 The equipment was evaluated for its ability to handle lift thicknesses of up to 12 inches based on achieving satisfactory in-place test results. However, the specific type of equipment used and the number of passes needed to achiave the required density were not recorded.
Category III provides a discussion of the generic implications of the quality control and testing factors qualification.
which had a primary inpact on equipment
- 2. The soils tests during plant fill operations
-s generally showed good compaction, and this infor=a-j O'
Revision 1 '
5/79 I-10 l
Sy,.....,v... . ,..,r, , , , - , , .,,,.,.m.,2 %,y y..m a rm,, w .n_,,,e,.~,,m.,__mw.m.--,-.,,_s_ .~...,_.-.,_..__....m_,______.,J
~ '
tien .was ;utilised by field personnel in determining the amount of direction necessary. Soils operations no physical attributes are unique available to and there are ! personnel by which to supervisory check the quality of the .compactlye effort other than the test results. Each lift is subsequently
- covered by the. following lift. For most other -
work . (such as piping) , the results of the work
-' efforts remain visible (such as alignment at subassembly closure points), or subsequent inspections
~
- J can be made or repeated to verify the quality (e.g. , hydrostatic . tests, nondestructive examinations, L and functional tests). *~
C.
Actions Taken To Correct Deficiencies Associated With Settlement-Problems:
(The numbers below correspond to the. numbers under Parts A and B above.)
- 1.
Prior to the resumption of soils work in the plant area, compaction. equipment will be reavaluated or requalified as to material type (cchesionless 'or cohesive soil), lift thickness, number of passes or rate of coverage (i. e. , compaction effort) , and compaction achieved based on field and laboratory density testing. This will be documented.
- 2.a. Permanent fill operations will not be conducted n unless a Field Soils Engineer is onsite to provide technical direction for the operations. SCM C-
- i 211-9001 adds this requiremant. In addition, a Soils Engineer from the 3echtel Design Section will be assigned ~ to provide an overview of tdue field operation. The duties and responsibilities of these personnel will be defined prior to the resumption of soils operations.
' 2.b. C7Co will implement overinspection for soils p2acement, utilizing a specific overinspection plan.
D.
. Corrective Action Taken To Preclude Recurrence Elsewhere:
(The numbers below correspond to the nu=bers under Parte A, 3, and C above. )
- 1. A review of specifications and procedures used'f6:
4 construction will be =ade to identify all construc-
- tien equipment requiring qualificacion. This review will be completed by June 29, 1979. '
- 2. The duties and respensibilities for field engineers and field crafts supervision are defined in Field I-11
,,y,,O - g f e-ge yg- t w'y' " F -T'"Pf F-NM*'**FOC'** #9
_ _ _ . . _ _ _. .-.m . _ - - _ _ ___
l
+ . ,
Procedure ??G-3.000.
4 This procedure will be reviewed by May 31, 1979.to assure the clarity and completeness of the definition.of duties and responsibilities, although there is no apparent ^
need for improvement at this time.
e 9
e
/
t 4
0 ij I-
,3
' S e
I .
O i
i I
e I
f l-t e
I I-12 g
j[ .
-n,,,,, w-r,rr-w,,,,,~.. - ,. n - n ..,,-,- e.,e.-,-- - -..,.. - . n n,- -. m.n.,n,c.,,,....~+..,~.,,-.,,, - ~ ~ -.. . - - - - - . . --,--.< .--
. _ . ~ . ~ . - _ . . _. . .
I i
- d 7- -
(s_ CATEGORY III QUALITY CONTROL AND TESTING ACTIVITIES A. - Deficiency
Description:
- 1. Inadequate Quality control Inspection of Placement I I
Of rill ,
- 'Bechtel Quality control inspection of soils work
). did not identify deficiencies which may have.
contributed to placement of fill that appears to have densities. in place that are lower than those specified. 'T
- 2. Inadequate Soil Moisture Testing Prior to 1978, moisture content was controlled by
- tests taken after compaction. Few or tio tests were taken en the fill prior to compaction, as required by Specification C-210, Section 12.6.
Attachment 1-7 describes ~ the methods that were used for soil control during the various stages of toil placement.
3..
Ince;rrect Soil Test Results
- e. A review of soils test reports indicates that -
there are some. reports which contain' errors and 4 inconsistencies in the data. Technical direction, surveillance, and test report reviews by Bechtel
- Quality Control did nce identify these errors and inconsistencies.
l In. addition, a preliminary review of these reports also' indicates other possible problems with the compaction test data. Attachment 1-8 presents the preliminary findings of this review.
- 4. Inadequate Subcontractor Test Procedures U.S. Testing's QA Program, Revision 6, dated Karch 20, 1979, did net provide procedures or 1 instructions for the ic11owing areas:
- a. Developing and updating the family of proctor curves;
- b. Visually selecting the proper proctor curve:
l l
A Revision 1.
~ 5/79 I-13
-,J_.__,_.___.._...._____..__...____..._____,_._...__.._.__.. _ ._ _
. . . - . . .. . - - = . .
3
'"'i c.
Developing _ additional proctor curves for j changing frequencymaterials curves; occurring between ncemal d.
. Alternative methods.of determining the proper laboratory maximt;m density where visual comparison'is not adequate. '
3pecification is an attachment G-22, Revision 1, dated June 22, 1973, the requirements for U.S.to specification C-208 and specifies Testing's QA Program.
Section 3.1.5 of Specification G-22 requires that this program provide instructions, procedures, and drawings, although it does not specifically call 3 out the requirements of Subparagraphs a through d listed above. r" B.
Discussion Implications: of the Deficiency, Its Scope, And Generic numbers under Part A above.)(The numbers below correspond to the
- 1. .
t The inspection for soils was acecmplished' by surveillance which did not require extensive documentation'o~f inspected. the specific characteristics In other constructic- areas for which surveillance is employed, acceptance ts based on
' the final inspection of the physical characteristics s e-~s af ter completion of the construction activity and
( the final inspection results are documented on a characteristic-by-characteristic basis. As such, e the application.of a defect prevention surveillance .s is not a' generic problem where fina1' inspections of record also exist. This item is considered to have generic implications in areas where inspection of processing methods, equipment, and personnel during construction is intended as an inspection of of record the specifics. requiring clear direction and recording 2.
Prior to 1978, Section 12.6 of Specification C-210 was interpreted by field personnel as felless: ,
"during compaction" was interpreted as the entire
. process of placing, compacting, and testing fili.
The density moisture test, content was measured during the which was taken immediately after
, compaction. Therefore, by field interpretation, the moisture and the fill was content notwas measured "during compaction" Reconditioning was done tested after intesting.
its icose state.
of moisture measurements taken for each timeA summary .
< period of construction is given in Attachment 1-7.
When cohesive' soils are used, moisture control in of minimizing the construction impactthe of performing borrow areas
/
Revision 1
.I-14
. . . - , . . . . . . - ~ , . . . . _ , . . . _ _ , , , . , _ _ . - - ~ . , . _ _ . . . . _ . . - _ . - . - . _ _ _ . . . - . - _ _ _ . . . . . _ _ _ - _ _ _ . _ . ~ . _ - . . - . _ - . -
(m) 3s s' moisture conditioning in the area whe$e fill is being placed and compacted. -
The specifications, as now revised, require that the' moisture content for cohesive soils be within
+2) of optimum moisture at the time of field Eensity testing. The specification further states that field density tests are to be taken i= mediately !
following' compaction.
" Meistupe conditioning of soil (preconditioning of j material) is unique to fill placement and is, therefore, not generic to other areas or disciplines.
- 3. e~
Bechtel's quality control of testing performed by, the testing laboratory subcontractor included steps to verify that the test results were reported-as either percent compaction or relative density (as appropriate to the material being tested), the r
' specification compaction requirement was met, the meisture content was within .the ' required limits (when required for, cohesive soils) , and the report form was properly completed providing date of test, location, elevation, and laboratory chief's signature attesting to procedure compliance. -
L ['~ This item is considered -to be potentially generic
! \ 'to other testing perfomed by this subcontractor.
l It is not considered generic to the. activities ^
performed by the nondestructive examination (NDE) subcontractor, as indicated by 'recent' monitors and audits as follows:
- a. Since January 1978, there have been ten audits of the NDE subcontractor's operations '
completed by CPCo, Bechtel, an Authorized -
Inspection Agency, and the subcontractor's management. The findings resulting from i
these audits do not indicate any significant or repetitive problems.
- b. Bechtel Quality Control surveys the NDE subcontractor's testing operations and reviews di all Q-listed radiographic film for nal acceptance.
I' ,
- d. CPCo CA provides an overinspection of NDE on a sampling basis.
O s.
s I-15 _
..__En ~., - _ . __.._.._,.,.-..i_. __ ..-. _ ._ -.__ ._..~._. ______ _ _ _. _ _._-_.
.. . H
-4. The inadequacy 'of tha test ~ 1aboratory . subcontractor's i n( test procedures is considered to be potentially i generic to other testing performed by this subcon- !
It is not considered generic to the tractor.
testing performed by the NDE subcontractor for the ,
reasons cited in Part 3.immediately above.
C. Actions Taken To Correct Deficiency Associ'ated With The Settlement Problems (The numbers.below correspond to ,
the numbers under Parts A and B above. ) ;
l'.a. PQCI C-1.02, Compacted Backfill, is being revised
/ to include a Daily Soil Placement Report, which is to be used in.each area where soils work is being performed. This report will include:
e--
(1) Area sketch showing areas of placement;
~
(2) Identification of equipment being used; (3)' Identification of supporting personnels (4) Recording lift thickness measurements (by elevation differences) which are representative of the fill being placed;
['
-( 5 ) Compactive effort used (rate of coverage or number of passes); -
L( '
' ( 6 )- Location by grid coordinates and elevation of ^
all tests taken and testing frequencies.
1.b. Bechtel Quality control " surveillance" will be changed in 'PCCI C-1.02 to " inspection" for inspections of record prior to the resumption of soils operatiens.
1.c. As previously noted under Category II, Section C.2.b, CPCo will perform overinspection on a sampling basis. - i 2.a. SCN C-210-9001, issued on March 29, 1979, and SCN C-211-9001, issued April 4, 1979, provide more direction at to the manner in which moisture is to i
l be controlled in. the field.
! 2.b. Bechtel 0 tality Control will continue to review !
field moisture and density test results to verify . . l that moisture content is within the required l l moisture limits. When test results are not accep-t table, the area affected will be identified to the Field Soils Engineer for appropriate action. The corrective action taken will be documented by '
b s; s t
A. .
I-16
?
. , , .,.--,m . , - , . . . . . . . . . . - , , . - - - . . . . , , , , . , . - - . - ~ - _ . . , , . . _ - . , . - _ _ . . . , _ , _ , , _ . . . ~ . . . , , . _ . _ , _ . . _ . . . . - . . . ~ - ~
- 1
< l 4 Bechtel .aality control on the Daily soils Placement Report,', Discrepancy Report, or Nonconformance.
-( Report, as appropriate.
2.c.
In addition, when cohesive material is used from borrow areas and stockpiles, moisture tests may be taken for production control. Such information will be provided to the Field Soils Engineer for his evaluation of the need for any preconditioning of materials prior to placement and compaction.
Final acceptance of moisture content will be at '
the time of compaction testing, as required 'hy the specifications.
/
- 2.d. The CPCo commitment given in Section C.1.c above
.also applies here.
ar-3.a. An in-depth review of testing and test results is being conducted by Bechtel. The Bechtel Geotech group is leading the investigation. This investi-
, gation will include:
(1) Borings taken in areas placed throughout !
construction; (2) Test' pits; '
(3) Laboratory tests on samples from borings and f-ss ,
test pits;
\ -
- ( 4 )'
- Analysis of past test results (Some preliminary s esults are given in Attachment 1-8.);
.(5) overlay plots of all tests.
This will-be completed by July 31, 1979. ,
3.b. PQC: C-1.02' is. being revised to improve the clarity of the specific items covered by Bechtel i
Quality control's inspection of U.S. Testing's i
soils compaction test reports.
3.c. CPCo will perform overinspection of the U.S. Testing soils testing activities and reports, utill:ing a specific overinspection plan. ,
.4.a.
Selection of proctor curves will no longer be a
~
problem because each field density test will be accompanied by a separate laboratory standard ,
compaction test which will provide a direct comparison.
' This has been directed by a letter to U.S. Testing and has also been reflected in SCN C-208-9004 dated April 13, 1979.
l s_. I-17 P
e
[ _
. ~ . . . . . - _ . . ., - . , _ , , , . . . . . . , . . . . . _ _ , . . . _ . . ..._..__,.._..~...._.._,._....._.__..m_..~..
l l
'4
( .. .
4.b. An in-depth audit cf U.S. Testing's operations will be performed by 3echtel by May 31,.1979. 1 I
This for any audit otherwillprocedures.
include an' evaluation of the need l
D.
Corrective (The numbers Actions Taken TotoPreclude below correspond Recurrence the numbers under Elsewhere:
Parts A, B, and C abovt.)
o 1.
Bechtel Quality Contro has initiated a review of
, .all active Quality Control Instructions (QCIs) .
l This review ia being performed to identify those QCIs similar to PQCI C-1.02 which provide for defect prevent. ion surviellances.. Modifications 4
will be made co these QCIs to distinguish between - *~
the defect' prevention surveillances and the final Laspections of record, recognizing that the final inspections of record say be made during or at the completion of the construction activity. The final inspections of record will be required to be
' documented, whereas the surveillances for defect .
prevention will not be required to be documented.
- 1979.
The review is scheduled to be completed by June 29, i
Modifications to CCIs will then ecmmence as l1 ,
, necessary in accordanace with ST/ PSP G-6.1.
- 2. No additional ' action is required.
f\~- .
3.a. Quality Control Instructions will be evaluated to ensure that.the documentation characteristics a I
which are to be' inspected (i.e., review callouts) j are clearly June 29, 1979. specified. This will be completed by i 3.b. The laboratory testing subcontractor is also
- performing other testing work, such as that for concrete splices. materials and reinforcing steel mechanical Through reviews of test results, test procedures, equipment used, and personnel performing the . tests, similar deficiencies as addressed above are not apparent.
5 l
l 3.c. An in-depth Bechtel CA Project and Engineering
[ audit of U.S.. Testing operaticas covering testing and implementation of their QA program will be l conducted in late April or early May 1979. This audit will consider generic elements.
- 4. No additional action,is required..
l' ,
, j 1
1 1
Revision 1 i
. 5/79 1
! I-13 I e: .,
.. . . ~ ~
l
. 1
,A '
/
- 5. Additional Actions Applicable Across the Scard s
.b N a.
- During May and August of 1977, a review of
'all CC:s was performed jointly by C7Co and Bechtel to accomplish, the following: I l
(1) Delineate inspection technique (visual,
. measurement, or visual and measurement);
(2) Assure the existence of adequate inspection criteria (reference specifications, drawings, etc, as required);
/' (3) Modify the inspection record to require that the QC Engineer utilizes the acceptance criteria as stated in the inspection source document .c and records the actual results ; .
(4) ' Delineate interfaces; (5) Clarify inst:uctions to the Bechtel Quality control Engineers (6) Clarify the scope of the inspection. {
- b. C?Co Project Management and QA reviews field
' procedures '(new and revised) and CPCo QA g'~ . -
g reviews GCIs (new and revised) in line with
- 3echtel Defore release.
,3 j c.' In 1978, C?co implemented an overinspection plan O to independently verify the adequac '
and the Bechtel inspection precess,ywith of construction
- of civil activities. Reinforcing steel andthe exception embeds were covered in the overinspection. C7Co, however, has audited and surveilled other civil activities numerous times, as indicated 'in the individual engineer's activity legs.
d.
C?co reviews ensite subeentractor CA' manuals and covers their work in the audit process.
e.
An ongoing effers is improving the " surveillance" mode called for in the QC:s by causing more specific accountability as to what character-r istics are inspected on what specific hardware and in some cases changing " surveillance" to.
" inspection."
t 4
O
.a,
?
i f.
Bechtel is woiking to incorporata scienti'ic sampling plans .for inspection areas, whereas the existing practice is to use percentage sampling.
4 e
s I
e a-
- I e
4 e
t
+ 0 s
, 8b 4
O 9
4 I
e r
e i
i I-20
- t. '!
I { . -
l .
I <> /,
mn==+t,+ $ , sp + y w w r,e . eng g- e e, ymeyee wwa, y, .-e e sp., w-e , *yge =ne ww e w.,.p .we i-re-- c vamsce. -we- + ._ww-==.=-_w=we-a=w_- ---m---+--
4
. _m .
s . .
CATIGCRY'IV QUAI.ITY ASSUnNCE ACTIV TIzS A.- Deficiency
Description:
- 1. Inadequate Corrective Action For Repetitive Conditions
- considered There have been to benonconfor: nances which could be repetitive.
- NCRs documenting these nonconformances include, but are not limited to, QF-29, QF-52,-QF-68, QF-120, QF-130, CF-147, QF-172, QF-174, QF-199, QF-203, Audit Findings F-77-21, and F-77-32, NCR 421, NCR 686, NCR 698,'and NCR 1005.
- Quality Assurance Department Procedure C,101, .
Revision.1, Paragrapa 1.0 states, in part, "This procedure provides a mechanism for identifying quality trends, and initiating corrective action to prevent recurrence...."
The reviews ~made in accordance with the procedure did not identify the need for additional process p- corrective actions beyond those which had been i
(
taken already as part of the dispositions for the individual nonconformance reports.
- 2. The Bechtel Quality Assurance Audit and Monitor i Program did not identify the problems relating to the settlement. This lack of identification of problems by the audit program contributed to a conclusion that soils operations were adequately
. controlled.
B. Discussion Cf The Deficiency, Its Scope, And Generic
!. Implications:. (The numbers below correspond to the numbers under Part A above.) '
- 1. ' Bechtel implements a trend program to assist in I the determination of additional actions needed to I correct repetitive.
, all noncompliances, problems. This program includes -
i including CPCo NCRs and AFRs.
The repetitive problems concerning soils operations vere included in this. program, but the 3echtel and I CPCo individuals responsible for review of the trend program outputs did not identify the need l for corrective actions in addition to those already
- t. <
taken. This item could be generic to other areas l
where repetitive nencenfor: nances have occurred.
l
["1 I-21 t I l
l
. . . ~ . , . . , . . . . . . . . . . _ , _ . . . _ . , . _ . , _ . _ . _ , . , . . _ . , - , _ _ . _ _ . . _ . . . , _ _ . . , _ . _ _ . . . . _ ~ . _ . . _ _ _ _ . . _ .
i -. . ,
W t
- ~. \
f
)
In addition, the CPCo program to detect significant I j
conditions adverse to quality did not identify a ;
need to take corrective action beyond that oucLined '
in OPCo NCRs and AFRs.
- 2. The use of auditing and monitoring to detect such problems is considered to have possible generic. ;
implications in other areas, even though it is .
recognized operations.
that an audit program only samples
) :,. C. Actions Taken To Correct The Deficiency Associated With The Settlements (The numbers below correspond to the numbers under Parts A and B above.) c ,
- 1. See Section D.1.a and D.1.b below.
I
- 2. See Section D.2 below.
D.
- Corrective Actions Taken To Preclude Recurrence Elsewhere:
(The numbers below correspond to the numbers under Parts A,'B, and C above.)
-i l
.I 1.a. An in-depth review'of the Bechtel trend program data will be undertaken by Sechtel QA management to assure the-identification of any other similar-
\ areas that were not analyzed in sufficient depth
- in the past reviews. This will-be completed by.
- June 1, 1979.. If'the results of this review ^
indicate a need for additional corrective actions, l these will be taken as required by the existing i program.
1.b. An in-depth training session will be given to Midland QA Ingineers covering the settlement
- problem and methods to identify similar conditions in the future. This will be completed by June 1, i
1979.
- CPCo Quality Assurance personnel have been directed i
to require timely corrective action when the purpose of the corrective action is either to prevent recurrence of the nonconformance or to acquire additional information as to the nature or degree of the nonconformance.
' increase their awareness of the settlement problem and discuss auditing and monitoring techniques to increase audit effectiveness. This will be done by June 1, 1979.
A I-22
.! i
Attachmen.t.E 1
- HIDI).3D FROJICT .RZY. B ySAR SICTICN RITITJ:NCIS RZY. C s Job 1*o. 7220 l
Section No. Rav.
Section Titis Originating Discipline -
The folleving documents were teviewed wh114 preparing the above titled section a
of the FSAR (indicated by Section No. , Rev. No. , etc.): ,
- 1. Ra;;ulatory Culde 1.70, Rev. 2. Section
- 2. NRC Standard Review Plan, See:1on 1
- NRC 3 ranch Position Papers 3'.. DEL Safety Evaluation, Section
..I
- 4. PSAR Section or Questions-
- 5. Unincorporated SAR Change Notica .
Incorporated by This Tax l 6. Unincorporated SAR Change Notics .
r A Considered '
'Q)
- ~
- 7. Regulatory Guides No./Rav. - -
I 8.
Project Regulatory Guida. Position *
! Considered. *
- MA . TZS *
- 9. Rasponses to NRC Regulatory Guide ,
Quesclans No.-
, 10. Supplanantal Invironmental Report Section
- 11. Final Environaantal Report Section 1 }.2. System Description /Rav.
5
(
r
~
- 13. Dvss. or Specs./Rev.
^
y 14. 3ESSAR Section Reviewed f' 15. 3ESSAR See:1on Adapted - -
3ESSAR See:1on Found Non-Applicabla Secause M
Originating Ingineer
.- ' CEC 23:
73AR Coordinator i
l 7 .
t l
, ,,,,,wwn,..- -+-+,.~~==+ee-=--*-~w+m*w>=#"' "* ** ** " """"" ~***"""~ ~
4 I
I L .. ,
Attachment 1-2 e
p .
V.
xIm D n uzC:
4 FSAR INTERTACI ROU*INC St.I?
j ,
Attached is the following TSAR Sub-Section(s) for your reviews
- t t
1n.xi .
Nt2GIR(S): rav. -
i Plassa return to , 8th floor, after review is completed by your disciplans. Plassa keep routing slip with the FSAR text aatarial. Plassa initial all comments for histor=
ical tracking purposes.
In ordar to be able to maintain our FSAR schedule, all conussats must be recursed no later than five (3) verking days after the
- issue data below. k*e appreciata your cooperation in expediting .
- review and return to us in the shortast possible c1=s. --
t
. nank you, FOR INT-ORMA710N ONLY
[- s FSAR Administrator COORDINATION PRINT .
JOB 7220
- Comuments Refer nuestions to .
I . . r, DATE
\
' TC tnt?! A t. tA?1
- l Architsch i j ' Civil l Cont ci Sysl l
- 'l tiectrical I j Ceotech I
< l.'uc E=g
,, .. Plant Deserl
. Mechse.ieal Don Riat FSAR Coor I ret'.:~ to: by -
CINDY TINZ G.
.(
9
- =-v v ==* - .. .. .. ,. . , ,, , ,,
- .s a
,__- .. . . - . . . _ . . _ . . - .. . . _ . . . _ . . . . . _ = _ . _ . _ . . . _ . . . . . . . . . _ _ . _ _ . . _ . . . . . _ . _ . . _ _ _ . , . .
_~.....;
Attachment 1-3
. . ~
MIDI.AND PROJICT TSAR INTEXTACE CCMMENT C.CSURE Job No. 7220 .
Date Seh.tton, No. .
Rev.
Section Title t
- L Origtsating Discipline
- . The above titled section has been reviewed by the following discipifies.
The initials below, of the ECS or his designee,* indicate satisfactory resolution of his 3:oup's commants.
- 1. -
. to
.3. ,.
- 4. .
l . ..$. '
I \j ,' .
- - Prepared:
. Origist. ting Engineer .
? .
Approved:
Disciplina Team Leader.
t .. ,
t '.
y ..
- g S
g .
\
a
- + - . =r . .. ; . ,n . . . . - , , ,.. .
a I
1
. ~
Attschment 1-4
=
, 7... .
IfIDLufD PLuff ?SAR m m c;c I m 'S COM!Z:l! C1.CSURE Job No. 7220 ,
,Dats
- . . i .
Section !*.o.
a.
Section Title
! Originating Discipline I
' i .
The above titled section has baan reviewed by the following chlaf engineers and all comments are closed. Original DR Ta are attached for the project
, filas. .
l 1; .
l- . -
2..
3, . .
p I The tax changas required to resolva Chief's Coments have been coordinated o
as sacassary vich the following affected disciplines. The initta.ls below, of the ICS or his designes, indicata ' satisfactory resolution of the Chief',s ,
, comments which aff act his discipline. . .
'y .
2.
4
- 3. <
[ . . .
Preparad '
,-- - Criginacing F.nginear l
. . Approved:
Discipline Tasa Leader .
I p
l .
l l
q ... .
l
~
antt;uottra T/coewsn..Jett LIsr .
Hsniano 3&2-t'sAu l (Sosted by sectichel .
closed peas.onalbility by
. rage / Ases/ hissing Date Aa,and-hc.1j an 12hli E lias , la fos sat ion pu. Co=inany arousi s.e n t 3
1.2 NEO Egnalpment location figure sowise'Draulng M-19 af/S scciatel PD/M f 1.2-22 to eliminate incoagalete eactione (V)
.t.S.S 1.5-3 Bloudown foscas on' Resulte og reactor internale and cose 06/60 D&W -
intaanale and core analysee .
(Licenelng tenue 1) .
1.7 TDE. ItsFAS Stel lube all Revise J-237 J-238 and J-233 04/79r Bachtel Cs 1.7-10 li us.pe legio 41agrams witta regard to RAS and actuating ,I Pt tube all punaps 1,3-11 (QCR 211.124)
- 4
- l t 2.5.4.33.1 2.5-69 Sanctamagts locatione $ntavey settlement misamuremento Nf3 Dechtel CV/C7 (Tut. 2.5-14A) Will be subo!Lted a
l ,
yearly sant!! ra-escial operaLlom 2.5 TBL Contact stresses and trovide taltimate bearing capacity Sf/s Bechtel CV
+
g 2.5-14 esitimate bearing capaotty and f actor of safety for Stie diamel for foisndatione supporting ganarator ban!! ding, solid reduaste i
g eelento Category I and 11 building, an2 condensates primary..and i
s t r asc t ua es horated water stora.je tanke (footnote 2)
$ (8 iceneleg leeue 44) .
e .
! , 2.S YnL Idealised soit profile trow!de awar.go valises for layere 07/79 sechtel CV I
- 2.5-11 and pasametaae A and B I
3.5 rio Licensing cammitmenta s&W to rawlene f!Ouaea (M-4S througia H-49) 04/797 B&W a
- 5 3.5-10 esguisment . 3 oca tione (Refer to Bochtal-123S. 2-22-79) tiarougle for elas!!e protecticas l 3.5-14 study 3.S #80 menator besilding newlme figures te indicate chaages et/s tactatel 20 "
b' 3.5-50 inteanal alma!!e in plant layout and minelle protection tt aouuta s t eady damigst (H-41 tlas'oisgle M-49) rn i a 3.5-h4 D*
. B i .r.
I
- gs j 3.4.2.5.1 3.6-9 ripe brealt locatione Finite element amanymie on primary loop. 07/19 Dechtet at n al
- S&W (ett. Vaanson) lisould e data!!cd (JFK) i enalyste of pipe atross, raJ!al and M
, antal (A) 'a 8
t a
geh.et 13 Sewiston 19 i
3/19 t
- p. x
\ ..
V I
i
, e -
l __ __- ___
3 _ -
.I ,
- 9 ,
! gg - PSAR COftll1N13T LIST 2 gg l ,I - St(!Iors (Dunst lett kl PSAR rect af v. atlP0milslLily 988P018540N- 3
- =
314Iu5 EO(Um(MI .84~ .
(
g .
G ,p 3.2.3.1.n3 A s/s sse ss medes test et the s ea s t e n i 3-35 4 -p
- lasesposated
-' enJ intesasta l a be las pos t ea med... es&a sostlea 8 653 -
l flaal =estaliano la slew ulti be 4.4.2.5 $ 454 .
i ;
de tes almed when the tests are , new a 3 655 j sempleted..
- 41&
-SST
-s II
,* 3.2.3.1.14 1ha seasles tale paint la 141.54 8.18 3-3S e -kC- laserposated #144 Ch 15 $4 '
sated poues. and the enslava owes- ) &&S
? peues whic h t o 1844. ul t i met b e tee De s &&&
I .
enseeJed aaJas any senditlea. 3estien 3a e I &&2 4.6. 1.4% ! &&)
3.2.3.2.4 At the pseasat slee. en amates q
5 seapotes almulatlea le belas do.elopeJ 3-64 4 -u laserperated fida Sostlose j &&
i -
8.1.4e 8 &&T
. to meetuate the pasfessanse of the went i emi.ea la 4e ,sen . s anse,. ihte . 6.2.t.3.2e 1 460 a :3 n.w e analysis ulti be used te -seesents ste '1 64, Igg
- it.a t a Jesun ta steam set tet selsts se 85upp 2 to s 616 that smatlas el the sese utf 4 be 1. E . A . e l 8 4)! gg l
!* essemplished. M8dlAad Plant ! 61 j Datts & L !s ! 613 1,a hat. I 4 14 f.
. July 49118 8 435
! 3.2.4 5 the seestes latessel seepensata es e 3-45 4 -le I' laeospesated
}
5
. I' dealsmed to meet the segulsesents #1Aa Sastlea 8 &1e
, spastiled in aestlea 3.2.4.8 et the
- 3.9.5 8 < -
. p1Aa. .
Aew 6 8 480
- le 1T 441 i
' 88
- i i.
- Datastal e.s the seasles tat.snes. 3-66 4* s v-a - gr-al closed a-1pos $8 beltlas allt be sub jec t e d to alsid I est qua li t y seats e B s eguis ematte to in- 88-1823000012-48 8 ause a ts us t us a l latessity. Ine botta deassiben 1 &S&
b ut8a be lasposteJ for austose S tau tesgeles and i 483, Badisa t tsaa e s tes all tahalsatten .
lesblas so- E ets j gulsomental l 649
- 8.a epasattena 3.a.e been semplet J.
testones 1
I losgue values ulig 6e speelgged ges ! Sto the flaat anae= Ley to de atop f ut s - leapestlea la i 49
! ba t tlas sepokality. All f astenes s alas la thle 3 492 4 s 8' ulti be lesk velded to laamse assembly ' E-Spes. 4 191 a
gg latessity.
- 495 I
- 496 gg
- su - .
y as i
l v si j =
{ .
~
I, ~,
u.
lee bN hh -
l
. 0 - -
~
i t
. t i
1 i
- Holature Measurements to Aid Compaction Control for Final Acceptance i.
j .
Loose Fill As Practical Prior to During '
Time in the Co action l Period Borrow Area Cong> action
?
( 23) (_25) Moisture Denalty i Prior to y No measurementa No measure- No measure- Measurements Tests taken 1 August 1, taken ments taken 2
1977 ments taken taken (smois- (density
. ture con- . controlled 1
trolled here) here) '
j August 1, Haaaurementa No measure- No measure- .Heasurements Testa taken j 1977, to taken, but not sments taken ments taken taken winter of (density j compared to controlled 1977-1978 laboratory j standard here)
)
, 1978 to Heasurements were taken and No measure- Measurements j 3/29/79 Tests taken controlled in at least one of menta taken taken (denalty
! these areas .
~
controlled
! ~
here). .
3/29/79 Measurements Measurementa No measure- Measurements Testa taken ;
j may be taken may be taken ~ ments taken- '
taken (mois- (density
! ture con- contaalled l
trolled here) here)
I
~
i l
1 Attachment 1-7 L
~
l i
l'
/
Attachment 1-8 Page 1 of 9 l .
, PRELIMINARY RESULTS OF REVIEW OF COMPACTION l l SOIL TEST DATA '
Described below are preliminary findings:
e Indicated in the chart below and attached Pages 2 through 9 are examples of certain laboratory standard compaction tests which were used many times more than would be expected. Many tests plot outside the appropriate zero air voids.
curve.
Approximate Approximate Soil Class- Number of Number of Times
! ification Times Outside zero j Standard Refnrenced Air Voids RD-61 556 -
RD-59 65 -
RD-55 555
- BMP-270 220 85 BMP-271 135 50 BMP-269 225 20
, BMP-277 150 70 BMP-278 80 45 l -
e The time span over which standards were used has l
l . been found to be as long as 24 months.
e Ratesting of failing tests may have improperly used different standards with lower maximum densities and resulted in passing tests.
e Certain errors in actual calculations have been discovered.
e There is some evidence that proctor curves that de not represent the materials may have been erroneously selected.
e There are indications that moisture readings obtained I with the Nuclear Moisture-Density Device might be in I error.
l . .
r i
I i '. !
a . .. i l
N 1
'1 H STCG3Ar. CF CC3PACTIC3 ICE CLASSITICATION 2061 TCP THIS CLASSIIICATION, MAI LA3 D1! DISSIT! = 125.3 I R A .1 C E , CC3?. HIST : TEST COUNT i < 55. 2.9 16
,' 55-50 1.6 9 i 60-65 31 17 j 65-70 3.c 19 70-75 3.6 20 l 75-80 u.9 27 8C-65 12.1 57 85-90 10 6 59
' 90-95 14 6 81 95-100
- 14.9 83 l
f' 10 C - 10 5 105-110.
12.1 6.7 .
67.
37 110-1,15' , 4.5 25 , t l 115-120 2.2 12 120-125 13 7
, > 125 1.8 to
5 )
- Q/
a HISTCCEAM CT CCMPACTION'TC! CLASSITICATIC;. 2059 TOR THIS CLASSITICATIO::, MAX Ll3 DTT DI.1SITY = 125.3 l
l
. B A.TCE, % CCMP . HIST : TIg! CCUNT I
< 55
. 3.1 2 55-60 .0 0 i 60-65 .0 C 65-70 3.1 2 70-75 1.5 1 75-60 u.6 3 80-85 u.6 3 85-90 7.7 !
, 90-95 6.2 4
.95-100 16.9 11 -
. 100-105 10 8 7
[Q-)
105-11C
- 15.4 10 ,
110-115 10.8 7
. I, 115-120 4.6 -
3 i 120-125 3.1 I
{ > 125 7.7 5 TCTAL CCUNT CT TISTS a !$
I 6
l AMAC2Mrr! 1-8 PAGZ 3 CF 9 l
l e
i O
s I
t e-m..-.-e-,we..,-.mw-w, -
,->-,wr.wv,,e e e, er -,w -,w. e,r ,+.ve,-,-,--,er..-w,,,r.r .r,=g-,,~*
i 1
i HIITCCPA5 CT CC3? ACTION TCP CLASSI!ICATIch 5055 l
TCE THIS CLASSITICA*ICb, M AX LAi ORY DENSITY = 109.7 1
l l
............................................................. I RANCE, % COMP. HIST % TEST CCUNT l
< 55 .h 2 55-60 .0 0 60-65 .2 1 65 70 - 1.4 2 7C-75 4 2 75 80 1.2 12 80-85 3.4 19
- 85-90 a.0 22 90 95 10.3 57
.95-100 11.9 66 100-105 15.5 86 105-110 13 .5 75 11C-115 ,12.4 69 115-12C 10 3 57 120 125 6.7 27
> 125 7.6 42
... ...............~..-...... ............................
TCTAL C0CET CT TESTS * !!!
9 A "l'ACHMCIT 1-8 ,
PAGZ 4 OF 9
..__... . . _ . . . . _ , - . . _ _ - . . _ . . . _ . . . , _ - . . . _ . . - _ _ - . . . . _ . , _ . . . . _ . _ _ _ _ . . . . _ . . ~ _ . _ . . _ _ _ _ . .
C' b,
.li ~
.I i
m x
M S I E T U R E - 3]E N S I T Y FOR Eb M P 270 L
, g ATTACilHENT l-8
- i. m y
PACE 5 OF 9 O
)
H vg x 5 {i.v :x s
- h,..
ele s x
x x kx x
$5 Li x 1 g* ---x x Y 1 fl
- x x x
. >c X X gr o x -
F1 '_5 XI X l.1 -
- u 8B
, Jo D_ i 19- .
i 2 H
- 4. s 9
! lll x
e 484 til 5 e u it.llit afl.D D ;2.l10 A*t.U U a
16.0 0 18.0 0 ID.DD 82.00 6*t.itu ~ I6 DD t
s -
NHISTURE C E1NTENT, %
~
, 1 ti.
lI B I 5 T L.l R E - )) E N S I T Y- FOR Ib M P 271
! Y t
y y ATTACHMENT l-8
- a. y ,
5'
- X PAGE 6 OP 9 X
- {*
. a y I
- t. Ij- XX X
- p X y xl x X y -
X # X
.j i I t '!
til f XX 4
y k -
Z- YX u X X gg
' X
,. u X X Y X *
- X tr 'd _ , ,
+
I n ns-X X X l'l XXI XI
. It '.
gu i, "' X X X .
t z X 3 11 5.
cn 9 X e as y X
s i S o;
c3 9
' u till til. tin 12.011 l's.3 H 16.0 0 18.0 0 du.00 22.00 2't.00 26 HH j iIDISTURE CONTENT, Fd -
i i
O
^
p o O
v
_ L.)
U -
j
- M O I S f LI R E -Il E N S I T Y- FOR Eb M P ~2 6 9 i
} I! ,
ATTACilHENT l-8 a
$ D ,
PAGE 7 OF 9 i i s
te U I."E- X D. -
i p' X fg E' I
[ XX
- p xX Li y*X k
- 1 n *X
--I Xy X i > C' X . d l tr u' h
- Y 1
, R ai-
- X X Xg y X
1.1 U *k yf{ X IE ci '
w*--
X i J ci- X AXy
- 11. a X '
- I 91 -
i Z
[ ll X i
! U yy X
! 'i' X
- X
- X y
i I!
I ci y-i -ti 110 li DD 10.0 0 15.0 0 t's.D D 15.0 0 1E.00 I0.00 Ii'.D D
~
Ii.DD l MMISl uRE CHNTENT, 2
=
1 1
. a 1
=
a r l\
l *N l a a
\ b b 3" 2 O
-l N !*
O w '
m l
< c. .N
'3,i h < N b o.
l <
' b c a j
~a >
^
E E M
=
J .
H EZ Y y f f H M
- . M WM . !u N. M y M a F M lc L ml M L7 2 j
M M Z ,4y pMh ,) '
-b.
L: ,
&M M -
M M M
My c: C r
r g
M M y '
jE i-f ., W W N l b M
[ M M
M '
[
=
MM x =
- M -c
' M M l '~ M
? M
~r -
M _
h .m t 7, M
- l'
'E i-a u .r. .u==> uu : uu ::: w;. . . , . ..... . . . . -
o u n ei. au:, .u :
Jac 4A_=N32 whC 3 b c-N!
t 1
l.
t t
. . . _ _ . , . - , ,. ~ , . . - . . .- . . , - . - , . . . . . , , , . . - _ , _ , . . . - . . . . . . . ~ . . . . . . . - - . . . _ . . . _ _ _ . . . . , . ~ . . . _ . - _ . ~ .
s O \
U 4
s i
j M S I S T LJ P E -II E N 5 I T Y' FBR (b M P .2' 7 8 .
U a X 1
e- ATTACitMENT l-8 i
i PAGE 9 OF 9 o y X k o- X Xy L1 ru- y i
(L -- X IgY l" x f Ill o X
5 -
! ZT X XX IJ X I'l I *X xIk i
>u x Yxx y i
II 9 1
I'l T - y i y g y y
, y XXI
! It x x
- l .13 - x 1
nI=s x -
i % %
! 2 i I3 X X y
l u X
- 9
~
I i
o i H X l 18 I O '- u . r , ,
. ~ll 1111 eD llli 12.0 0 l*s.D D IG.IID 80.00 10.0 0 82.00 i*t:D.. )fi.Dll FIMISTLJRE CONTENT, !6
ATTACHMENT 10 !
i e l
( .
C ( --
1
._ q JUN 6 1979 l ', 7 l
Docket No.
+
Docket No. 5 330 l l
Consume'rs lower Company-ATTN: Mr. Stephen H. Howell .
Vice President !
1945 West Parnall Road Jackson, MI 49201 i
Gentlemen: l This' refers to the inspection conducted by Messrs. E. J. Gallagher and E. W..K. Lee of this office on May 14-17, 1979, of activities at j
the Midland Nuclear Power Plant construction site authorized by NRC l Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion I of our findings with Messrs. T. CoiKe and D. Miller, others of your staff, and others of the Midland site staff at the conclusion of.the f" . inspection. .
l Thq enclosed copy of our inspection report identifies areas examined -
during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appendix A.
l This notice is sent to you pursuant to the provisions of Section l 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of l Federal Regulations. Section 2.201 requires you to subtit to this !
office within. thirty days of your receipt of this notice a written statement or enplanation in' reply, including for each item of noncom-pliance: (1) corrective a cion taken and the results achieved; (2) corrective action to be taken to avoid further none:mpliance; and (3) the date when full comp 2fance will be achieved.
In accordance with Section 2.790 of the NRC's " Rules of Practice," !
Part 2, Title 10,. Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room, except as follows. If the enclosures i
(
. . . _ . _ . . . . .- - _ . . . - _ _ _ _ - - ~. . -- . .
i a
l
? I k t A/ p!! r
,a n is ,j;n' g{.
Consumers Power Company NO 13 I3 contain information that you or your contractors bslieve to be proprietary, you must apply in writing to this office, within twenty
- - days of your receipt of this letter, to withhold such information
- from public. disclosure The application must include a full state-ment,of the reasons for which the information is considered proprietary, and~should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
L We will' gladly discuss any questions you have concerning this,
' inspection.
Sincerely,-
G. Fiorelli, Chief Reactor Construction and Engineering Support Branch
Enclosures:
- ( 1. Appendix A, Notice of. Violation
- 2. IE Inspection Reports
'No. 50-329/79-10 and No. 50-330/79-10 i . .
-ce w/encls:
Central Files
' Reproduction. Unit'NRC 20b l PDR- '
- I,ocal PDR .
NSIC- '
, TIC Ronald Callen, Michigan Public Service Commission Dr "Jayne E. North Myron M. Cherry, Chicago ,;
t i
RIII RIII RIII R.III / RIII RIII -
y c T.
Gallagher/sr RIy,is 4h ,fy ::L*
Danielson 1
Fiorelli Cook Vandel l~1YJJ 1. I, h 9 LI.ee 5/31/79 */ / ' <
t o
r , + r.rssU,v~n , e r. e .e n ,, _, -
- n. v , &, , v.w.w a en , vr '
..,-v,,.e...--+,r-ea..r m .w, ,,r--w-sm ,,_ _n,.~,--,,,,,--n_
fm \/~'i] ( **t m .--
<!..'..'.., 7 . : ~ . ,, ' ..J,' l s
( '
(\ (
\
~ w-. I l
Accendix A NOTICE OF VIOLATION 1 l
l Consuc: n Power Company Docket No. 50-329 Docket No. 50-330 l
Based on the results of an NRC inspection conducted on May 14-17, 1979, it appears that certain of your' activities were not conducted I in full compliance with NRC requirements as noted below. This item is an infraction.
{
- 1. 10 CFR 50, Appendix B, Criterion III, requires, in part, that measures shall be established and executed to assure that regu-latory requirements and the design basis as specified in the ,
license -applicat. ion for structures 'are correctly translated into' specifications, drawings, procedures and instructions.
Also, it provides that measures shall be established- for the identification and control of design interfaces and for coor-dinates among participating design organizations.
Og t
CPCo Topical' Report CPC-1-A policy No. 3, Section 3.4 states, in part, "the assigned lead design group or organization (i.e.,
the N3SS supplier, A&E, supplier or CPCo) assure that designs and u terials are suitable and that they comply with design criteria and regulatory requirements."
CPCo is committed to ANSI N45.2 (1971), Section 4.1, which states,'in part, " measures shall be established and documented to assure that the applicable specified design requirements, such as a design basis, regulatory requirements . . . are correctly translated into specifications, drawings, procedures, I or instrhCtiCnS "
l' Contrary to 'the sbove, measures did not assure that design basis.were included in drawings and specifications nor did they provide for the identification and control of design interfaces.
As a result, two inconsistencies were identified in the license application and in other design basis doc'.unents. Specific examples are set forth below.
- 2. Construction specification C-2, Rev 11, dated November 16,
'1978, Section 11,1 specifies material for prestressing system sheathing' to conform to ASTM A-366-6e or 63, 22 gauge cold rolled carbon steel whde FSAR Section 3.3.1.6.3 O
Q- l r
790gpM MvP6 DF
i,
\f C l * - - . , -. . .
I i i. L. , .
~
Appendix A -
2-indicate the sheathing material to be material meeting the- ,
requirements of AST!! A-513, Type 1, Grade 1010-1020 or AST!! A-53, Type E or S, Grade 3.
- b. Construction specification C-49, Rev. 2, Section 6.2.2
. specifies the chemical limitation on the corrossive protec-
, tive filler material for the prestressing system-to be 5 ppm for chlorides, nitrates and sulfides while FSAR Table
.3.8-25-indicat.es the maximum allowable to be 2 ppm (chlorides),
4 ppm (nitrates) and 2 ppm.(sulfides). ' In addition, the Inryco Quality Control manual requires the material chemical
, properties to be the same as FSAR Table 3.8-25.
f-
\
. a 1
4 l
l
' /%
( (
\
U.S. NUCLEAR REGUI.ATORY COMMISSION OF7 ICE OF INSPECTION AND ENTORCEMENT REGION III
' Report No. 50-329/79-10; 50-330/79-10 Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82
. x.~ ~
Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI -49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Midland Site, Midland, Michigan Inspection Conducted: May 14-17, 1979 Inspectors: E.'J. Gallaghe
~
x I/ O Q
p) .
\v 411& .NNm- . -
jgsE. W. K. Lee 6/3/77 l I )A .
Approved By: D..W.Yayes.;#C ////79 Engineering Support Section 1 /
Inspection Summarv Inspection on May 14-17, 1979 (Reports No. 50-329/79-10; 50-330/79-10)
Areas Inspected: Reactor coolant pressure boundary and safety
- related piping; pipe welding work activities; containment prestressing work procedure, work activities and quality records (Units 1 and 2); ;
status of soils work activities; concrete expansion anchor installation procedure (Units 1 and 2). The inspection involved a total of 44 inspector-hours by two NRC inspectors.
Results: Four areas were inspected. One item of noncompliance was identtiied in the areas inspected. (Infraction - failure to properly translate FSAR design requirements into specifications and procedures.)
(O 770703D633
. . _ _ - _ _ _ . . . _ _ _ _ __ ~ ,. _ . . . - ._ - _. __ _. -. .. _- . _ _ _ _ _ . _ -
M
,<-~, .
.(
DETAILS-
- i. .
. Pevsons Contacted
- ' Principal Licensee Emplovees (CPCo) i
- D. B.' Miller, Site Project Manager
- T. C. Cooke, Project Superintendent
~
- D. , R. Keating, QA Croup. Supervisor
~
i
- D. E. Horn', QA Engineer
- R. G. Wollney, QA -Group Supervisor. ,
- B. H. Peck - Construction Supervisor.
, t R. Ostrowski, QA' Engineer
' Bech'tel Po'ier Corporation
- W. L. Barclay, Project Field QC-Engineer s *E. Smith,; Quality Assurance
- 0.'H. Holman,-Field Superintendent
- R. W. Shope,. QC Supervisor- <
- A. 0:eroff,lQA Engineer
, *A. J. Boos,1 Field Engineer- -
. ' KRC. Resident Inspector. -
- R. J. Cook .
- Denotes those present at the exit meeting.
- Functional or Program Areas ' Inspected Details of functional and. pr'ogram areas inspected are documented;in Sections I and II of.this report.
4 4
2-q
-m,,..,-.,,,r,..~ . - - , , - , , . < , ~ ~ , . . - , . . _ , , , ,,,,,--.-. - .. ,_...n.,,,.....,..,......-...--...~._,_.~....,__.,_,__.-~._.
l l
e
( ^(
Section I ,
l Prepared by E. J. Gallagher Reviewed by D. W. Hayes, Chief Engineering Support Section 1
~~
- 1. Review of FSAR Containment Prestressing S*; stem Commitments (Units 1 and 2)
The inspector reviewed FSAR Section 3.8.1.6.3 (Prestressing System) in order to verify consistency with the site implementing procedures. The following apparent conflicts exist between the FSAR commitments to the NRC and site procedures and specifica-tions for the prestressing system:
- a. The FSAR states, " Tendon sheating is galvanized, spiral wrapped, semi-rigid, corrugated tubing. conforming to the material requirements of ASTM A-313, Type 1, Grade 1010-
/'~'g
, 1020 or ASTM A-53, Type E or S, Grade B.
N/
Contrary to the FSAR statement,' Bechtel specification C-2, -
- l Rev. 11, dated November 16,_1978, Section 11.1 requires = .
" material of sheaths shall conform to ASTM A366-66 or 63, .
22 gauge cold rolled carbon steel." In addition, the Inryco Quality Control Manual C2-146 requires sheathing to be of ASTM A366 material as well.
- b. FSAR Table 3.8-25 indicates the maximum allowable chemical limits for the tendon corrosion protective grease to be 2 ppm for chlorides, 4 ppm fot nitrates and 2 ppm for sulfides.
Contrary to the above, FSAR Section 3.8.1.6.3.1 pe rmits the maximum allowable limits for chlorides, nitrates and sulfides.co be 5 ppm. In addition, Bechtel specification C-49, Rev. 2, Section 6.2.2 specifies the chemical limita-l tions for protective grease to be 5 ppm for the above chemicals. . However, contrary to the Bechtel specification.
Inryeo Quality Control Manual C2-146 requires the protective gresse to have chemical limits the same as TSAR Table 3.8-25, i.e. 2, a and 2 ppm for chlorides, nitrates and l
1 sulfides, respectively.
V _
3 t
g- g g e=w e er e e,s-i, -*-w>-s * - - - * -v sm3,-tm g- g -Gm--p-v>- eg *-y
4 4
_[-
.( (
. Based'on the above, measures did not assure the design basis included in design specifications were translated into the license application which resulted in inconsistencies between design documents and the FSAR. This is consid' red an item of .
noncompliance with 10 CTR 50, Appendix B, Criterion III. l (329/79-10-01; 330/79-10-01)'
- 2. Review-of QC Inspector Qualifications for Containment Prestressing System Work Activities (Units 1 and 2)
The: inspection requests to review the personnel qualifications of the Bechtel QC inspectors who would be inspecting the pre-stressing system work activities. .The following was determined after reviewing six personnel qualifications:
.a. It was apparent from the personnel work experience records that none of the six inspectors had any prior experience with prestressing systems,
- b. Training-of the six inspectors was given by an individual 4
that likewise had no prior experience on'prestressing systems.
I The above deficiency in personnel training and qualificatio'ns
- was also identified by the licensee quality assurance group as an item to be resolved prior to performing any further work activities.on the prestressing system. This area will continue to be reviewed in followup inspections of the prestressing system.
- 3. Review of Quality Records for Containment Prestressing System (Unit 2)
! The inspector reviewed the following quality records relative to the containment prestressing system,
- 4. ifaterial Certification (1) Tendon '4 ire - a review of the physical and chemical ,
test resu hs was performed on tendon wire hest Nos.
-9399, 9582. 9521. 9578, 9507 and 9t76. The results
-meet the requirements of ASTil A421, " Uncoated Stress-Relieved '41re for Prestressed Coacrete."
(2) Tendon Bearing ?!ates - hett codes GB. 03, G:1, GR and
'G.N were found to meet the requirements of A3T t A-36, "Specu:.cacun :or structural Steel."
.L.
,. , - ,. . . - -,...,a..-~..,__,. -.,.._.,--.._,__.._...__..a-..-._.-~ . ~ . u . _ _ ,,: ~ . - ..- -
l l
k-w - .
" -/ T ,
\.
-v J' (
-(3) ' Tendon Shaathing - the-tendon sheathing records were l acceptable according to the-requcraments of ASTM 1 A366-66, 22 gauge, cold rolled sheathing.
(4) Tendon Shop Head Anchorage - heat No. 53315 meet the
. requirements of ASTM A-322-64, " Hot. Rolled Alloy Steel Bars."
(5) Tendon Bushings - heat Nos. 55984, 7836 and 15008
, . , were reviewed and found acceptable to the requirements r of ASTM A-322 using material ~AISI 4142.
- b. Performance Tests Construction specification C-2, Rev. 11, required the
-following quality tests to be performed and submitted prior to. fabrication of the prestressing system. The test results were not available onsite at this ' time. The licensee indicated that these quality records-would be' made available during the next NRC inspection.
(1) Section 10.1 requires certified testing at low f ~g
- temperatures to substantiate that the anchorage .
/ ' assembly including bearing plate is capable of trans .
\,_,sl* mitting the ultimate load of the tendon to the struct6re without brittle failure. The lowest service temperature for the anchorage is -20 7.
(2) Section 10.3 requires the-sheathing filler retaining caps to be tested to substantiate that the cap will not fail or leak when test to 150% of required pumping pressure.
(3) Section 14.6 requires button head rupture tests from each reel of wire .to be submitted a quality control record.
Since the above three items were not available for review, this item is considered unresolved pending submittal of the records. (329/79-10-02; 330/79-10-02)
- 4. Observation of Containment Prestressing 3/ stem (Unit 2)
During the course.of_the NRC inspection C?Co and Bechtel issued a "Stop '4erk Order" on any further prestressing system work activities. The reason for the stop work accordir.g to QA stop a
r 5-
, L L ., , ~, .,w, , -?,....... , . , , , , - - - - .-,~- - - - - - - ~ ~ . - - = - - - - - - -- --- +- ~~
N
,d f
(
I work' report No. 5.was-that the " status of Inryco furnished Field Installation Manual which forms the basis for Sechtel '
< Field Procedure of Installation and Quality Control (PQCI) is _
l
. questionable." In' order for work to resume, it was stipulated ,
-that it would be necessary to resolve questions regarding )
Project Engineering (Bechtel) level of approval for Inr/co
~ furnished Field Installation Manual and establish approved instructions for installation and inspection including. revising l Bechtel Field Procedure and Quality control instruction.
Due to the above work stoppage, observation of the prestressing worn activities could.not be performed. This. matter will ;
continue to be-inspected to verify an adequate procedure.and inspection program is in effect for.the containment prestressing system work activities.
- 5. Status of Safety Related Soils Work-Activities TSafety related.' soils work is not preceeding until-certain
-corrective actions are taken in order to resolve a number of ,
previously identified deficiencies. Some of the licensee's !
. corrective' actions include:
I 'a. Identifying all conflicts within.the PSAR'or.between PSAR and FSAR.
- b. Identify.'all conflicts between PSAR/FSAR and site procedures.
- c. Re-evaluate the use cf Zone 2 random fill material as a backfill material.
.d. Assure that interpretations to the specifications are resolved.
- e. Establish a single soils engineer responsible for the soils work activities.
- f. Re-evaluate the capability of the equi..ent being used to meet compaction requirements.
- g. Assure proper tests are performed.to document acceptability of in-place soils,
- h. Assure each nonconformance report is properly dispositioned. r During this inspectien, the NRC inspector observed air bubbles percolatin:; irem the ground in the safet/ related tank farm area. A closer inspection indicated that nr and water was j D?
O ,
yt
-, .- - , -,- . . . . . - . . . . - .,-_,-.-_..-,...m..__...~...._.. _ . _ - . - . . . . . . . . _ _ . . . _ . - . . _ _ .
i'1 j
A Q ,
(
being moved through the previously compacted soil materials in this area, It was observed that soil materials were being moved by this condition and leaving; voids beneath concrete foundations for the tank structures.
This condition was brough; to the attention of CPCo project manager on May 16, 1979, On May 17, 1979,' the project manager and superintendent responded by visually observing this condition.
They concurred with the NRC inspector that the condition was serious and that damage to.the compacted soils may have occurred.
The extent of the movement of materials was not known.
LThe NRC inspector indicated to the licensee that in order to substantiate that the materials and compaction of the soils had not been disturbed, additional soil borings-and test pits would need to.be performed. The NRC took photos to document the soil condition and movement of soil materials.
It was also brought to the NRC's attention that CPCo QA department had brought this condition to Bechtel QC months earlier, however, no corrective action had been taken to correct these adverse
,__ conditions.
I Ty 'During the exit meeting the CPCo site superintendent gave a l
copy of a letter to the NRC requiring the contractor to relocate the air line embedded in the fill and turn off the air to the existing linel This letter also indicated to map the location of all air seepage areas so that additional ' soil borings could be taken in these areas.
- 6. Review of Procedure and Observation of Testing Concrete Excansion ,
Anchors l The inspector reviewed specification C-305, Rev. 8, " Installation
' and Testing of Expansion Type Concrete Anchors" and Quality l Control Instruction (QCI) -1.50, Rev. 4. In addition, Field Change Notices C-1835 and C-1846 to specification C-305 were l also reviewed. The following specific observations were made:
t
(. ' a. As of this inspection, the specification did not require a
! means of inspecting or identifying the embeddment length of the bolt. CPCo had identified this item in QA request for evaluation on July 2S, 1978. Bechtel then issued SCM
-C-305-9002 o requite a permanent length identifier to be stamped on the bolt. CPC0 required Bechtel to develop a i procedure for ultrasonic testing to reinspect the length '
of the bolts installe! prior to this time. <
-4 s_ - -
7-i.
l g9imr -
+4'e-3 i,gan.p 9 ym9 my +m gi-gn, y'e3, pm-,9 ,,yg- r eygps.-m .sw,.,f-- i,4 tu g- .-*ppse,- 9g 4w mebegem.dn---eN ""M'tNN' W--t*wgP e
- Wag %*rT *+'98***G t* + - -
- 9 m **'"M
.. = . . - --
. -tn\. f
-Q <
l 4
- b. Specification C-305, Table 4.1, lists certain test torques for acceptance of concrete expansion anchor installation.
The inspector requested-to review the test data which demonstrates that-the torque values specified develop a tensile capacity equal to or greater than the design load as required by IE Bulletin 79-02. This data was not readily.available and will be followed up on subsequent inspection as per the requirements of IE Bulletin 79-02.
- c. Specification C-305, Table 3.2, indicates the allowable design loads for the Hilti HDI Drop-in anchors (shell type anchors)-and the required tensile test load. The test load specified is only approximately two times the design load. For example, 3/4" anchor in 4000 psi concrete the allowable design load is 3.2 kips while the tensile test load is 6.0 kips.
IE Bulletin 79-02 states that the licensee should verify that the ultimate load for'shell type anchors is five times the design load. This was indicated to Mr. W. Bird via telecon. .This will continue to be reviewed as.per IE Bulletin instructions.
,a (w During this, inspection, the NRC inspector had a telecon
, with the CPCo QA supervisor relative to the requirements '
l of IE Bu*lletin 79-02. The following is a summary of that discussiorf:
(1) The licensee is required to identify base plates that are considered flexible according to the criteria. set forth, i.e. if the unstiffened distance from the attachment to the edge of the plate is greater than two times the thickness of the plate it is considered
- flexible and requires evaluation for adequacy.
L (2) The licensee must verify that the ultimate load for wedge type anchors is four times the allowable design L load and the ultimate load for shell type anchors is l
five times the design load.
(3) The design requirements for the anchor bolts should be described for cyclic loading conditions.
(4) Ve ri f t/ that design requirements have been met through i existing QC documentation that (a) cyclic loads were l
considered and (b) bolts installed are *.he specified
- design sis
- e and type.
h
. l-
, - , . - . , . = - . . - - . - ._ - ., .. - . - .. - - - .. - . _ .
. - . = - -
i.
)
i )
i g . I.-
t The'following is the.}GC's understanding of testing requirements:
. The essential- requirement is that the: licensee justify the adequacy of proposed testing program. IE Sulletin 79-02 suggests ,
an acceptable sampling program to test one anchor bolt in each.
, base' plate. Other: approaches including a statistical sample to
, provide a 95*. confidence level that fewer than 5* defective anchors are installed are equally acceptable. It is suggested
- that any test sampling program chosen should be on an individual system basis-when a significant ~ failure rate is'.found, an
~
~ ~~ increased. sample size must be taken or 100*. testing may be required to assure systems' capability.
G -
U '
4 l
4 I
f l -<
o 9-L o I-i i
- g. g..,., a *.---,.yv.,-y ,**+r,-,--.,- m w , - , e , w w ww . r%.v. ,-r w e ,.,,v e,-e,-.w.,.v., .w.-m-e,+n..,,,, .-c.wrc,..me-,..,wbw.+-----*.-e-.ew.~,..w-,,,c.-.m.~.-.,,,,~e
PN.
-(v) .
Section II Prepared by E. W. K. Lee Reviewed by D. R.-Danielson, Chief Engineering Support
- Section 2
- 1. Reactor Coolant Pressure Boundary Piping - Observation o f Work and Work Activities (Unit 2)
The' inspector observed th'e two installed hot legs and the installed Reactor Coolant Pump No. 2P518 section. It was determined that the pipe runs were installed in accordance with the drawings. ,
No items of noncompliance or deviations were identified.
- 2. Safety Related Piping - Observation of Work and' Work Activities-(Unit 2) .
l
[
\
The inspector' observed wel) end preparation of weld No. 82 on l- sketch No. 2FCB36-S611-4-4. It was determined that work activities were performed in accordance with the applicable procedures and good construction practices were adhered to.
No items of noncompliance or deviations were identified.
- 3. ~ Safety Related Piping - Observation of Welding Activities (Units 1 and 2)
The inspector observed the following welding activities:
- a. Unit 1 Main Steam 3ystem Weld No. 15 on drawing ao. M631,
! sheet 1; l b. Unit 1 Decay Heat Removal Discharge System 'B' Weld No.
l 110 on drawing No. M610, sheet 6:
- c. Unit 1 Reactor Building Heating Ventilating and Air Cendi-tioning System Weld No. 25 on drawin; no. M512, sheet 3;
- d. Unit 0 Decay Heat Removal Discharge System 'A' Weld No. 13 on drawing no. M611., sheet t.
\
10 -
.,y. ...,-,%.w -.7.,.-, , -,~,,,,-.>w, ye ., .-..s., , . . . , m , ,..e.. .#y., , , . ,.~..,,,,-2,~w_,_ ,_.c., . , . , .w.- ,4m (
. .. .. - ... . . .-. .w i
c.
[
4 m
' 'y (
I It'was determined that (1) work was conducted in accordance !
with traveler; (2) proper welding materials were used; (3) !
welding procedure requirements were met; (4) work area was free I of weld cod-stubs and (5) physical appearance was acceptable. '[!!
.{
No. items of noncompliance or deviations'were identified. .j
- 4. Reactor Coolant Pressure Boundary Piping - Special Welding Applications t' Unit 2)
'The inspector observed ~ the following repair work activities: )
d
- a. Grinding and etching of cladding repair on weld no. WJI-l .
- b. Weld repair of' classing on weld no. WJ4-4. l f
It was determined _that .(1) work was conducted in accordance !
with traveler; (2) proper materials were used.and (3) procedure j requirements were met. !
l No items of noncompliance.or deviations were identified. g
/"'N 5. Safety Related Pip'ing - Weld Heat Treatment (Units 1 and 2) !
k a 1 While observing welding -4:tivities for items stated.in Ptragraph 3 of this report, the inspector determined that preheat met the welding procedure requirements.
No items of nonecmpliance or deviations were identified.
- 6. Reactor Coolant Pressure Boundary and Safety Related Piping -
Welder Qualitication (Unita 1 and 2) i The inspector reviewed qualifications records of welders who i performed welds identified in Paragraphs 3 and 4 of this report. !
It was determined that AS:1E B&PV Code Section IX requirements were met.
l No' items of noncompliance or deviations were identified.
l
' Exit' Interview The inspectors met with licenseeLeepresentatives (denoted under Persons Contacted) en .'!ay 17, if)~9. The inspectors sammarized the
! .secpe and findings of the inspection. The licensee acknowledged the findings as reported, l
f'^s .
i-11 f.
ATTACHMENT 11 p j_py
[.. .* p p h a.~T k, 1 we
) Bechtel Potuer Corporation
. 'O j
- t. Tt7 !ast !Usennower Parxway AUG1o..GN Ann Atoor, vienusan
== r o. secoo, woor umca .
g August 10, 1979 3LC-7993 Mi consumers ?over Company Mr. G. S. Iaelay a Project unnager AUG g g MS 1945 7ese Parnall Road QUA{Jg Jhekson, Michigan 49201
'dl0uNg g I./RANQ Midland Uni:s 1 and 2 Consumars ?cver Coupany 3echtel Job 7220 RZ7ITJ of U. S . ?!Smc e i r n AND LA30RATCET TISTS CN SOIT.3 Filas,0614/2801
Dear Mr. Keeley:
Actached for your records is cha complaced report dated July 1979, antitled "Raview of U. S. Testing 71ald and Laboracory Construe:1on Test Data on Soils Used As 7111." '
This report includes rasciutions to che questions :sised by Consumars Power personnel on the earliar draft report.
The report will now be sent to the subcontractor, United States Testing Company, Inc., for chair response to tha"fdsdings.
Yury cruiy yours,
^^
,., r -
? . 1. Mar':dJa2
? reject Manage:
- **W 9
- l l
.