ML20003H086
| ML20003H086 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/04/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20003H079 | List: |
| References | |
| 11510, NUDOCS 8105050076 | |
| Download: ML20003H086 (29) | |
Text
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KepplM O "P Consumers Power James W Cook O&h %ce Presdent - Projects, Engsnee sng an.1 Constructson General offices- 1945 Wes- Pernell Road. Jackson, MI 49201 + (517) 788 0453 March 4, 1981 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Concission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT -
INSPECTION REPORT NO 50-329/81-01 and 50-330/81-01 FILE 0.4.2 UFI 73*60*13 SERIAL 11510 References (1) NRC Letter, J G Keppler to J W Cook, Dated February 2, 1981 (2) NRC Letter, G Fiorelli to J W Cook, Dated February 5, 1981 This letter, including all attachments, provides Consumers Power Company's response to References 1 and 2, which transmitted the subject Inspection Report and Appendix A and B, respectively, and which requested our written statement regarding three items of noncompliance and one deviation described in Sections II, la, Ib, Ic(1) and le of the Inspection Report. It is noted for the items of noncompliance 81-01-01 and -02 that Appendix A provides a classification of severity level V, whereas the Inspection Report in the Inspection Summary, gives a severity level of IV for these items. L Per Reference 2, previous approval was given by Region III to extend the response date by one (1) week due to the delay in the transmittal of Appendix A and Appendix B.
The item of noncon.pliance (50-329/81-01-01, 50-330/81-01-01) concerning the lack of formalized procedures is responded to in Attachment I by stating that we are taking positive measures to improve the proceduralization of soil testing activities and to eliminate any questions of whether or not this is an item of noncompliance.
Our response to the items of noncompliance (50-329/81-01-02; 50-330/81-01-02) I and (50-329/81-01-03; 50-330/81-01-03) respectively, is that upon a more extensive evaluation by Consumers Power Company the noncompliances, as stated, do not exist. Attachment 1 provides the details of this evaluation and we l request that you reconsider the classification of these as items of j noncompliance.
Attachment 2 addresses the deviation (50-329/81-01-05 and 50-330/81-01-05) stated in Section II, le of the Inspection Report. Attachment 3 provides oc0381-0192a102
% iO 5 05007 .
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e SERIAL 11510 2 Consumers Power Company's response to the unresolved item described in Section II, Ic(2) of the Inspection Report. This letter also transaits the revised and closed Safety Concern and Reportability Evaluation (SCRE) No 5 for the Borated Water Storage Tank (BWST) ring foundation as Attachment 4.
Consumers Power Company Dai-d March h, 1981 By /U'L /. [
.L s / C// /(/:
G S Keeley For /
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James W oo , . c6~ President I
Sworn and subscribed to before me on this L day of March, 1981
_- J-lm / >~
J Notary Public, Jackson County, Michigan My commission expires September 8, 1984 CC RJCook, US NRC Resident Inspector Midland Nuclear Plant (1) i l
oc0381-0192a102
- Attachmant 1 Serial 11510 ITEMS OF NONCOMPLIANCE This response add resses the three items of noncompliance identified in the Notice of Violation, referenced as Appendix A in a letter f rom J.G. Keppler to J.W. Cook, dated February 2,1981, and attached to a letter f rom G. Fiorelli to J.W. Cook, dated Februa ry 5,1981.
These items of noncompliance are identified as:
l 50-329/81-01-01; 50-330/81-01-01 50-329/81-01-02; 50-330/81-01-02 50-329/81-01-03; 50-330/81-01-03 l
t and are further discussed in I&E Report 50-329/81-01; 50-330/i t-01, Section II, la, b, and c(1).
Each of the three items of noncompliance are responded to separately.
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Attachment 1 Item 1 ITEM OF NONCOMPLIANCE 023539 (50-329/81-01-o1, 50-330/81-01-o1)
The Notice of Violation (Appendix A to J.G. Keppler's letter to J.W. Cook, dated February 2, 1981), Item 1, states:
...the inspector determined that U.S. Testing Company has not established test procedures for soils work activities. The specification for testing, C-208, references ASTM standards for performing specific tests, but does not include procedural controls or instructions for imple-menting the tests.
Response -
! This statement was based on three observations, each of l
which will be discussed individually, followed by a response to the finding, and then a discussion of a related lo CFR 50.54(f) commitment.
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Attachment 1 Item 1 The first observation is found in the I&E Report, Section II, la(1), and states:
023539 i
While observing a laboratory relative density test (ASTM 2049) it was observed that the vari-l able rheostat on the testing apparatus was set at
! maximum setting. The lab technician stated that ASTM D 2049 requires the setting of the machine at maximum amplitude. It was determined that UST did not previously determine the rheostat setting that produced the maximum density for the material being used onsite. It was assumed by UST that maximum setting produced maximum density. Rela-o tive density tests are used to assure that the inplace field density meets the specification requirements.
Corps of Engineers Manual EM 1110-2-1906 dated November 30, 1970, Appendix XII, Page XII-8 states the following:
"It has been determined that for a particular vibrating table, mold, and surcharge assembly, the maximum dry density of a specimen may be obtained at a displacement amplitude (rheostat setting) less than the maximum amplitude of which the apparatus is capable; i.e. dry i
density may increase with increase in rheostat setting to a setting, beyond which the dry density decreases, therefore each laboratory should determine for its apparatus the rheostat setting at which maximum density is produced and use this setting for subsequent maxi-mum density testing."
Footnote on Page XII-8 states:
"It may be desirable to redetermine the optimum rheo-stat setting at the inception of testing for each major proj ec t."
U.S. Testing had not determined this setting nor did a procedural control exist for the determination of the rheostat setting.
Response
Midland project is committed to conduct laboratory relative density tests in accordance with ASTM C 2049-69, not the srps of Engineers Manual. AE';;M D 2049 provides the proce-d are to be used by the U.S. Testing lab technician, n determining the maximum density. The lab technic sa - as,
- .erefore, both correct and accurate in referring t- the l
rE7'i requirement that the vibrator be set at maximu, ampli-l :u .a .
, P00R ORIGINAL
Attachm2nt 1 Item 1 The inspector's dete rmination that U.S. Testing "... did not previously determine the rheostat setting that produced the maximum density. . . " is correct. Howeve r, U. S. Testing, did 023539 p reviously dete rmine the rheostat setting that produced the maximum amplitude required by ASTM D 2049.
ASTM D 2049-69, Section 3.1.1 " Vibratory Table", states in pa rt , "The vibrator shall have a f requency of 3600 vibra-tions per minute, a vibrator amplitude va riable between 0.002 and 0.025 in. (0.05 and 0.06 mm) under a 250-lb (Ill2-N) load..." It should be noted that Corps of Engineers Manual EM 1110-2-1906 November 30, 1970, Appendix XII, Page XII-5, Parag raph f requi res a va riable vibrator ampli-tude to a maximum of at least 0.015 in.with the same load o as ASTM D 2049-69. This Corps .of Enginee rs Manual requi re-ment allows a maximum vibrator amplitude less than ASTM D 2049-69 and also allows a maximum greate r than ASTM D 2049-69, which may be the reason for the statements quoted f rom the Corps of Engineers Manual in I&E Report, Section II, la(1). During receipt inspection (August 1, 1980) of the Humboldt H3756 vibrating table, it was determined that the maximum amplitude of 0.025 in. required by l ASTM D 2049-69 was obtained at the maximum rheostat setting. I Subsequent to the NRC inspection, tests we re pe rformed which again verified that the maximum rheostat setting yields the maximum amplitude on the relative density table used on the project. This is documented in U.S. Testing's lette r to L. E. Davis of Bechtel, Serial UST-J-100, Jan-ua ry 26, 1981. These tests will not change the yearly l recalibration of the vibratory table scheduled for August 1, l 1981.
Tests we re performed for the NRC inspectors, and presented during the inspection, which verified that the maximum rheostat setting provided the highest maximum density and conversely, the lowe r the rheostat setting the lowe r the
- density achieved. Thia provides evidence that, at least for
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the equipment used on this project, there is no difference between the ASTM method utilized on Midland project, and the Corps of Enginee rs methcd quoted by the inspector. It should again be reemphasized that ASTM D 2049 does not require the determination of a maximum density setting.
Although ASTM D 2049, Section 7, entitled, " Maximum Density Proced;re" provides adequate procedural control for the prope r dete rmination of maximum density, U.S. Testing issued OCP-10. Rev 0 (Quality Control Procedures for the Testing of Soil). This procedure was implemented on February 4, 1981, and in Section 7.1.1.5 states maximum amplitude (0.025" l single amplitude) is obtained at the maximum control dial i
setting for the Humboldt H3756 vibrating table in use on the Midland project.
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Attcchmant 1 Item 1 The second obse rvation is found in the I&E Report, Section II, la(2), and states:
While observing limited field soils wor # 2 3 5 3 9 being performed at the metering pits south of the essential service water intake structure at elevation 630' it was determined that samples used to perform relative density tests have been taken after the material has been compacted.
These samples should be taken prior to compaction since g rain size and gradations can be altered du ring compaction. The relative density test should be performed on as received material used prior to compaction. Grain size is one of the important characteristics of how soil behaves.
The inspector determined f rom a review of the available grain size analysis that there appears to be a gradation change of the material comparing before and after compaction.
A procedural control specifying where and when to taken soil samples should have been established.
UST does not have procedural instructions specifying the field technique where and when to take samples for density tests.
Response
The sampling and testing of structural backfill sand is accomplished in the following manner:
a) Upoti receipt , incoming structural backfill sand is tested for gradation in accordance with ASTM D 422.
, b) The material is stockpiled then moved to the placement site, placed, moisture conditioned (if necessa ry) , compacted, and sampled.
l c) In order to determine in-place density of the
- ma te rial, it is tested in accordance with ASTM D 1556.
f I d) At the time of the in-place density a g radation is l taken for information ( ASTM D 422) and maximum and minimum densities are deter:ined in accordance with ASTM D 2049.
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Attachmant 1 Item 1 The available grain size analyses reviewed by the inspector included gradations obtained f rom receipt inspections and 023539 gradations obtained at the time of in-place density tests.
The material gradations, at the time of receipt, show a fluctuation between samples of approximately ten percent for some sieve sizes. This is perfectly acceptable within the range allowed by the specification. The gradations, af ter l compaction, would be expected to show a comparable fluctuation.
l To look at one sample taken before compaction and another l sample taken af ter compaction and say that the diffe rence in l l gradation represents a gradation change of the material is l an incorrect usage of the data. Hence, it is unknown how the inspector made the determination that, "there appea rs to be a gradation change of the material comparing before and af te r compaction. "
A rigorous academic evaluation would ag ree that whenever there is handling and compaction of soil, a degree of reduction in pa rticle size occurs. However, this change in gradation is small, indete rminable f rom the data reviewed ,
and insignificant in comparison to the nonhomogeneity of the mate rial itself.
If the material we re tc undergo a significant g radation change during compaction, a sample taken prior to compaction would no longer be representative of material in place.
Dete rmination of in-place density, gradation, and the corresponding maximum and minimum density values af ter compaction, automatically accounts for possible g rain size changes in the evaluation of the in-situ relative density and provides the project with records of the actual properties of the mate rial in place.
, The second parag raph of the second obse rvation, ref e rs to procedural control. Specification 7220-C-211, Section 8.9.1, specifies that the testing f requency for all fills will be determined in accordance with their volume, or by the onsite geotechnical soils engineer.
Specification 7220-C-211, Section 8.10, requires that the onsite geotechnical soils engineer determine all density test locations.
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Attachmsnt 1 Item 1 Hence, procedural controls have already been established 0 2 3 5 3 assigning the responsisi11ty for determining where and
- when to take soil samples to the onsite geotechnical soils engineer, not to U.S. Testing. U.S. Testing's
, procedure QCP-10 (Quality Control Procedures for the I
Testing of Soil) implemented Februa ry 4, 1981, reflects these specification requirements.
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Attcchmant 1 Itcm 1 The third observation is found in the I&E Report, Section II, la(3), and states:
It was determined f rom discussions with the cognizant UST personnel that they have been performing in place density tests "at the direction of the onsite geotechnical engineer."
However, there are no procedural instructions as to what depth below the lift being compacted the test should be performed. A review of the density test reports indicate that they are not correlating the density test depth to the lift being compacted.
Response
The testing of soil materials is performed in accordance with Specifications 7220-C-208, Section 9.0 and 7220-C-211, Section 8.0. Specification 7220-C-211, Sections 8.9 and 8.10,specify that the f requency and location of the in-place density tests are to be determined by the onsite geotechnical soils engineer.
The minimum test f requency for field density and moisture content is given in Specification 7220-C-211, Section 8.9.
In accordance with that section, the minimum test f requency is dependent upon the extent of the area, compaction equipment used, and the volume of backfill material to be placed. Hence, according to the established requirements the density tests are to correlate to a
! volume of soil, not to a specific lift. Thus, it is l not necessary to test every lift nor to correlate the test to the lift being compacted. Any correlation that may be needed at some future date would be based upon the elevations recorded on the test report form.
It should be noted that by following Specification 7220-C-211 for placement of material and using the prequalified compaction equipment, all lifts of the backfill materials are uniformly compacted to meet the density requirements.
The practice has been to pe rform in-place density testing about 1 foot below the surface for sand and about 0.5 feet below the surface for clay. The dete rmination of the location (depth / elevation) of these tests is the l
' responsibility of the onsite geotechnical soils engineer in accordance with Specification 7220-C-211, Section 8.10.
The determination of where to take the density test (s) should be left to the judgment of the onsite geotechnical soils engineer and not proceduralized. U.S. Testing's recently issued QCP-10 reflects this responsibility.
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Attechmont 1 Item 1 Based on the three preceding observations, the item of 023539 nonc mpliance was stated in the I&E Report, Section II, la(1), (2), and (3) as:
l Based on the above, it has been determined that !
CPCo is in noncompliance with 10 CFR 50, l Criterion V (Procedures) in that adequate laboratory and field test procedures have not been established for the control of soil testing activities. (50-329/81-01-01; 50-330/81-01-01).
Response
o The procedural control for establishing the proper rheostat setting (first obse rvation) was provided by the " Maximum Density Procedure" in ASTN D 2049 which was imposed by the project specification (7220-C-208) cont rolling U.S. Testing's work. The periodic recalibration of this equipment was identified and controlled by the recalibration procedures.
There is, therefore, no evidence of lack of suf ficient orocedural control to accomplish the activities associated with the qualification, usage, and periodic checking of this equipment.
The project specifications put the responsibility for determining where and when to take soils samples (second observation),
including the depth for in-place density tests (third observation),
on the onsite geotechnical soils engineer. This position was established to have a knowledgeable, experienced individual in a position to exercise control and judgment over the soil ope rations . To further proceduralize the work in this area could negate the " active role" currently established for this position.
This response establishes that, in the areas questioned, adequate laboratory and field controls have been in existence for the soil testing activities. Neve rtheless, U. S. Testing
, has generated procedure QCP-10 to direct the testing personnel's attention to the already established requi remen ts.
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Attachmant 1 It;m 1 The I&E Report, Section II, la, continues:
D 2 3 5 3 9 CPCo response to 50.54(f) question 23, subsec-tion 3.11, page 23-31 states that "U.S. Testing was required to demonstrate to cognizant engi-neering representatives that testing procedures, equipment, and personnel used for quality veri-fication testing were capable of providing accurate test results..." This commitment has not been satisfied based on the above findings.
Response
. The quotation referenced above is, missing a key phrase. The full quotation is:
U.S. Testing was required to demonstrate to cogni-zant Engineering Representatives that testing procedures, equipment, and personnel used for quality verification testing (for other than NDE and soils) were capable of providing accurate test results in accordance with the requirements of applicable design documents.
The parenthetical phrase was omitted. This missing phrase specifically exempted the soils activities from this commit-ment. Hence, the inspector's findings had no bearing on the completion of this commitment.
Additionally, the preceding response to the three observa-tions concluded that adequate procedures existed to control the soil testing activities.
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Attachment 1 Item 2 ITEM OF NONCOMPLIANCE O23539 (50-329/81-01-02; 50-330/81-01-02)
I&E Report 50-329/81-01; 50-330/81-01 in Section II, Ib, states:
It was determined that U.S. Testing was using uncon-trolled forms to record quality control test results.
A binder was observed in the U.S. Testing lab which contained QC forms used to record test results. On the inside cover it stated that the index does not reflect the latest revision of each form. The cognizant lab personnel were not able to demonstrate that the latest revision of QC test forms were being used since there were no document control provisions established to control these forms. An undated U.S. Testing inter-office memo was presented to the NRC inspecter as the procedure to follow when receiving revised forms. It states in part, " log into controlled forms index". The inspector requested such a form index but did not receive it. There was no documentation onsite as to what forms are to be used for what test as well as what are the latest revisions of the forms.
Based on the above, it was determined that CPCo is in noncompliance with 10 CFR 50, Appendix B, Criterion VI, (Document Control) in that measures have not been established to control the issuance of documents which affect quality activities.
(50-329/81-01-02; 50-330/81-01-02)
Response
All forms in use were controlled. Each form had a unique identifying number and either the date of latest revision or a revision number (with the exception of forms MEI-115 and MEI-116 which were original issues and did not have revision dates or numbers).
The binder which contained quality control (OC) forms was labeled Controlled Forms Book. This book contained a copy of each form available for use and Controlled Form Indexes for several subjects (concrete, soils, etc) identifying these forms by name and number. The inside cover states:
" Midland Project Instructicn CONTROLLED FORMS BOCK
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l Attcchm2nt 1 Itcm 2
+.
The controlled forms indexes are lists of forms and need not be updated to indicate the latest revisions. A copy of the 2***** vi5i " ' ' *"Y f '" i" I23539 ded in the body of the Controlled Forms Book.
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All U S. Testing personnel we re awa re that forms a re con-trolled and the cognizant lab personnel (i.e. , lab chief, assistant lab chief, and records controller) we re capable of demonst rating that the latest revisions of OC test forms we re being used. As committed to the NRC during the Janu-a ry 9,1981 exit meeting,. the Midland Project Quality Assur-ance Department did a survey on actual forms being used against approximately half of the forms contained in the Controlled Forms Book for soils, concrete, and steel and found all forms checked were the current revisions.
The U.S. Testing interoffice memorandum referred to by the inspector was dated February 12, 1979, and was labeled Midland Project Instruction Processing New or Revised Forms and Documents. This inst ruction contains step-by-step procedures for handling forms and documents, and was signed by the laboratory chief.
Each QC form and worksheet contained the ASTM test method, by number, for which it was to be used, as well as an iden-tifying number for the form and either the date it was last revised or a revision number (with the exception of forms MEI-ll5 and MEI-ll6 which we re original issues and did not have revision dates or numbers).
Based on the preceding, there is no evidence of noncompli-ance with Criterion VI of 10 CFR 50. However, based on the inspector's concern for the lack of formalized procedures, stated in Section II, la, of the I&E Report, U.S. Testing implemented OCP-14, Rev 0 (Quality Control Procedure of Forms ) on Febura ry 4, 1981.
The Notice of Violation, Item 2, notes the following dis-crepancy which was not discussed in the I&E Report previously quoted, "There is no distribution list for the forms. . . . "
Distribution of the test result forms for soils activities has been: original to quality control with copies to the onsite geotechnical soils engineer, Midland Project Quality Assurance Depa rtment (MPQAD), CPCo-Project Management Organi-zation (PMO), and U.S. Testing's jobsite files. To add ress the concern regarding the lack of formal procedures, Change No. I to QCP-10, Rev 0 was issued effective Februa ry 26, 1981, to incorporate this distribution into the procedure.
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e Attcchm2nt 1 Item 3 ITEM OF NONCOMPLIANCE 023539 (50-329/81-01-03; 50-330/81-01-03)
I&E Report 50-329/81-01; 50-330/81-01 in Section II, 1c(1) states:
Quality assurance records for backfill work activities we re reviewed for completeness and compliance with licensee specifications, procedures, t
and commitments.
l Bechtel field instruction FIC 1.100, Appendix A, duties and responsibilities of the onsite geotechnical 1
engineer, Parag raph 18, requires that the onsite geotechnical engineer review and initial all acceptable UST test report forms.
ANSI N45.2.9 (Quality Assurance Records), Section 3.2.1, requires that " quality assurance reco rds shall be conside red valid only if stamped, initialed, signed, or otherwise authenticated and dated by authorized personnel".
Numerous UST density test reports were rubber stamped by the geotechnical engineer, however, none we re dated. In addition no procedural controls were established for use or control of the rubber signature stamp of the geotechnical engineer.
Based on the above it was determined that CPCo is in noncompliance with 10 CFR 50, Appendix B, Criterion XVII (Quality Assurance Records) in that the soil test reports a re not initialed or dated and there we re no established controls on the use of a rubber signature stamp. (50-329/81-01-03; 50-330/81-01-03)
Response
The referenced FIC 1.100 requirement was intended to direct the onsite geotechnical soils enginee r to review each test
. repo rt and to indicate on the report that he had done so.
The instruction stated, " initial", but signature or stamp are also acceptable methods of indicating this review.
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Attcchaont 1 Itsm 3 The ANSI reference quoted above has been taken out of context.
g 2 3 5 g g ene Thetest ANSIrepo standard rt is is referring being to what filled mustitbetodone out, for when be considered a valid quality assurance record (i.e. , the pe rson doing the test shall authenticate and date it). These test repo rts are valid quality assurance records in compliance with ANSI requi rements regardless of any commitments for a subsequent review by the onsite geotechnical soils engineer.
10 CFR 50, Appendix B, Crite rion XVII, requires that:
Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following:
...the results of reviews, inspections, tests, audits.... Inspection and test records shall, as a minimum, identify the inspector or data reco rde r, the type of obse rvation, the resuits, the acceptability, and the action taken in connectic a with any deficiencies noted....
The subject test reports are quality assurance records within the Appendix B definition, and identify the elements requi red by this crite rion. The " reviews" add ressed in the refe rence above is a generic te rm used in the same sense, and at the same level, as inspections, tests, audits, etc.
It is not intended to refer to the particular review and approval cycles that an individual quality assurance record, such as a test repo rt , may go through. Hence, Crite rion XVII is not applicable to the review and sign-off of a test report by the onsite geotechnical soils engineer.
Thus, ANSI N45.2.9 and 10 CFR 50, Appendix B, Criterion XVII, are not applicable as the detailed controlling requirements for review and sign-of f of test reports by the onsite geotechnical soils enginee r. Neithe r regulation requires control of signatu re stamps.
Any violation which occurred should be limited to permitting a signature stamp as a loose interpretation of the FIC 1.100 requi rement that the onsite geotechnical soils engineer
" review and initial" all acceptable U.S. Testing test repo rts .
The ANSI requirements for quality assurance records indicate tha t forms of sign-of f, other than initials, a re acceptable, but that it would also be advisable to indicate the date of rev iew. Hence, the " separate instruction to the onsite geotechnical engineer" committed to in the response to the 14
l Attcch22nt 1 Itc= 3 unresolved items of I&E Report 50-329/80-32; 50-330/80-33, will also address the acceptable ways of documenting this review and the need to indicate the date of review.
Th' * "*' ' "' ' ' *i'""*" ****P "**"" ***
1353B re sponsibility of the individual who = signature it bears.
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Attcchm2nt 2 Seriid 11510 DEVIATION 023539 This response addresses the deviation identified in the Notice of Deviation, referenced as Appendix B in a letter from J.G. Keppler to J.W. Cook, February 2, 1981, and attached to a letter from G. Fiorelli to J.W. Cook, Febru-ary 5, 1981.
This deviation is identified as:
50-329/81-01-05; 50-330/81-01-05
, and is discussed in I&E Report No.
50-329/81-01; 50-330/81-01, Section II, le The response to this deviation begins on the following page and is followed by a discussion of follow-up action.
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I Attachment 2 DEVIATION 023539 (50-329/81-01-05:50-330/81-01-05)
I&E Report 50-329/81-01; 50-330/81-01 in Section II, le states:
, CPCo response to 50.54(f) question 23, Subsec-tion 3.7, page 23-20, states that, "one full time and one part time onsite geotechnical soils engi-neer have been assigned." The inspector requested the qualifications of the onsite geotechnical engineer. A resume was presented to the inspector as representing the assigned individual to imple-ment the commitment in order to preclude future soils problems. This engineer is to provide the technical direction and monitoring of the entire earthwork process.
The resume that was presented was of an " Engineering Technician" with no previous formal education in engi-
- neering or geotechnical engineering. The engineering technician had nominally 15 years of field and labora-tory testing of soils.
This information was discussed with representatives of the NRC geotechnical branch. It was determined that CPCo committed to provide technical direction from a geotechnical engineer capable of being recognized and
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licensed by a state board of registration of professional engineering or equivalent.
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In view of the fact that adequate technical direction had not been provided per the commitment by CPCo in the 50.54(f) response it has been determined that CPCo is in deviation from a NRC commitment as described in Appendix B of the transmittal letter of this report.
l (50-329/81-01-05; 50-330/81-01-05)
Response
The purpose of the onsite geotechnical soils engineer posi-tion is to provide technical direction and monitoring of the entire earthwork process as a qualified representative of project engineering. The respons: 2111 ties of the onsite geotechnical soils engineer include assisting field engi-neering in the implementation of se:ls engineering design and specification requirements; r.c _fying the project soils engineer and quality control engi eer of any onsite soil-related activity not in accordanc> with the specifications, 17
Attcchment 2 drawings, or good engineering practice; notifying project field engineering and the project soils engineer of any 023539 construccion activity detrimentally affecting the quality of soil-related work; and documenting explanations, approvals, and inadequacies regarding placement of soils. The onsite geotechnical soils engineer monitors but does not perform the actual field and laboratory testing of soils.
A job description for the onsite geotechnical soils engineer (backfill and laboratory testing) position, including prin- ,
cipal responsibilities is provided as Appendix A.
The following are the qualification requirements for the onsite geotechnical soils engineer (backfill and laboratory testing) position:
- 1. Knowledge of "rocedures required for fill placement, compaction, und laboratory testing as required by the applicable specifications
- 2. Qualifications for this position are a recognized degree in civil engineering from an accredited college
- or university or a registered professional engineer; r and two years of field experience with soil compaction and laboratory testing on earthwork projects.
- 3. The applicability of field experience will be estab-lished through interviews with the soils engineering group supervisor responsible for the technical content of the work and with the geotechnical services manager responsible for staffing the position.
The onsite geotechnical soils engineer now at Midland meets the above qualification requirements.
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AttEchmtnt 2 Af ter stating the deviation, the I&E Report, Section II, le, contained the following statement conce rning follow-up activities: 023539 Subsequent to the inspection, CPCo informed the RIII office that a geotechnical engineer would be onsite beginning January 19 1981 and that job descriptions and qualifications for the geotechnical engineer for the speciality remedial work to follow would be developed. This action will be verified during subsequent inspection. I
Response
The following is a job description and definition of the qualifications of the onsite geotechnical engineer for the special remedial wo rk.
A. Purpose and Responsibilities The purpose of this position is to provide technical direction and monitoring of special remedial work which j may be required to repair or strengthen existing foundations t
of structures, tanks, and other facilities. This remedial work may include underpinning using piles, caissons, reinforced concrete, or compacted backfill.
i The onsite geotechnical soils engineer (special remedial wo rk) will be responsible for observing and coordinating critical operations of this remedial work, including inspection of subgrades and bearing strata, adequacy of l pile driving equipment and methods (where applicable),
! safety of tempora ry ea rthwork support, load transfer by jacking, settlement measurement, etc. Full-time monitoring of routine operations, such as pile blowcounts and compaction testing, may be delegated to the onsite geotechnical soils engineer (backfill and laboratory testing).
B. Job Desc ription Observes and provides technical coordination for critical phases of the work beyond the routine earthwork aspects.
Reports to project soils engineer and quality control any detrimental or inadequate work.
C. Qualification Requi rements l 1. Knowledge of design requirements and installation t procedures required by the type of remedial foundation work being constructed.
19
Attcchmant 2 <
2.
Qualifications degree for this position in civil engineering f rommust include 0f 3 5 3 9 an accredited college or university or a registered professional engineer; and two years of experience in the design and analysis of fcundations and soils mechanics.
- 3. The applicability of design and analysis experience will be established through interviews with the soils engineering grcup supervisor responsible for the technical content of the work and with the geotechnical services manager responsible for staffing the position.
D. Implementation The onsite geotechnical soils engineer (special remedial work) will be made available upon commencement of any special remedial work, and will be full-time at the jobsite during any critical, nonroutine phases of the wo rk.
Prior to January 19, 1981, a gectechnical engineer neeting the qualification requirenents for the ensite geotechnical soils engineer (backfill and laboratory testing) was present en the jobsite to perfor= the tasks indicated in Appendix A.
I 20
, Attacnm2nt J Scrial 11510 023539 unnzSotvro ITEx This response addresses the unresolved item identified in the I&E Report attached to a letter f rom J.G. Keppler to J.W. Cook dated February 2,1981.
This unresolved item is identified as:
50-329/81-01-04; 50-330/81-01-04 and is discussed in IEE Report No.
50-329/81-01; 50-330/81-01, Section II, Ic(2)
The response to this unresolved item begins on the following page.
21 1
Attachment 3 UNRES LVED ITEM 3539 (50-329/81-01-04; 50-330/81-01-04)
IEE Report 50-329/81-01; 50-330/81-01 in Section II, Ic(2) states:
Specification C-208, Section 9.1.3(d) requires the geotechnical engineer to review and evaluate test results when densities exceed certain values.
From discussions with the previous geotechnical engineer, it was determined that the evaluation consisted only of a check of the numerical calculations for numerical errors. If the calculations were correct the disposition was "use as is", this review does not meet the requirement to evaluate test re sul ts.
Subsequent to the inspection CPCo informed the RIII office that documented evaluations of the above would be performed. This is an un resolved item pending review of the evaluation (50-329/ 81-01-04; 50-330/81-01-04).
Response
The onsite geotechnical soils engineer provided the following explanation of the evaluation performed, by him, on all test reports indicating a density equal to or exceeding 101% or 105%, as appropriate, for the period April 16, '.980 to December 31, 1980. This explanation has been provided in a lette r, Februa ry 27, 1981, to the manager of Geotechnical l Services in Ann Arbor f rom the onsite geotechnical soils er.g inee r.
The following checks were performed on density tests equal
. to or exceeding 101% compaction for cohesive materials and equal to or exceeding 105% relative density for cohesionless materials:
- 1. a reasonable in-situ wet density
- 2. a reasonable moisture content
- 3. a reasonable in-situ d ry density
- 4. correct calculation of densities and moisture content
- 5. reasonable percent compaction for cohesive materials
- 6. reasonable laboratory maximem and minimum dry density using both the vet and d ry methods allowed for the relative density test
- 7. correct computation of percent relative density 22
Attcchm2nt 2
- 8. correct computation of laboratory maximum and minimum dry d'"Siti'5 0235%9 .
correct computation of average of both triais of maximum and minimum densities for use in computing relative density
- 10. consistent volumes and dimensions of molds and their respective weights
- 11. gage reading for measurement of consolidation similarity and for any indication of severe tilting of disk surface
- 12. test labeling and information consistent on all corres-ponding test forms
- 13. verification of equipment calibration The following additional checks were performed, by the onsite i
geotechnical soils engineer, to make a final determination of an acceptable test:
- 1. review of gradation analysis test (if applicable) to observe i any inconsistencies i 2. correct calculation of gradation analysis
- 3. compute percent compaction for cohesionless materials, and
- 4. a reasonable percent compaction for cohesionless materials.
l The onsite geotechnical soils engineer further stated that he had witnessed all field density tests performed, a large portion of all the laboratory processing of the field tests, l many of the relative density tests during the time interval indicated and found them to be performed with a very high deg ree of consistency with regard to established ASTM procedures and requi rements.
In the above statements, reasonable refers to comparison l with other tests, known information, and the engineering
, judgment of the onsite geotechnical soils engineer.
23
Att acheer.t L
- ^
Serial n to
% === SAFETY CONCERN AND "i!!"E s E"s f b= mun assmm t,_sm
~
' $_1 REPORTABILITY EVALUATION FACI 1
- u. HoW WAS CenCEF:: IDENT m tD, WHEN, WHERE?
As a result of the 50.54(f) commitments to do a TO MANAGER-MPQA structural reanalysis of Category I Structures (See Items 1. FRCm R 1. Rixford 14-7 and 48-2), the BWST ring foundation was reanalyzed OMCAT: W-W and values were obtained which were inconsistent with SCF2 " 5 previous values, and inconsistent with FSAR requirements. . 0: 15.1 , 0.L.9.L9 The results of the analysis were obtained 1-4-81 and dis- DATI RECEIVED:
cussed in a 1-5-81 CPCo/Bechtel meeting. The Project Manager attended this meeting and subsequently briefed 2. M C M P A Y ;O the Manager of Quality Assurance. WHEN? N/A BY WHOM? N/A
- 3. IS NRC AWAFI CF THIS?
YIS m NO WHEN? N/A (CONTINUE ON NEXT PAGE) BY ',.'HOye N/A 5 BRIEF DESCRIPTION OF CONCER'; - SYSTEM, CC'GONE;T, ACTIVITY, POSSI3LE SAFE". -w -
(ATTACH SUFFORTING DOCUME:.TS).
The BWST ring foundation was analyzed for several loading combinations including the dead load plus live load which was determined to be the most sesvere. The analysis was first performed using th: ::thrl: f 3C-TC" 't, ":
2 (thi: ::th:2 re: springs for soil /
structure interaction fri .;; ; ::icri .a.;), but gave displacement values inconsistent with anticipated and measured values. The analysis was then done using a finite element technique which gave consistent displacement values but forces and moments in excess of FSAR allowables. The values obtained from the reanalyses which have been done indicate an overstressing and, hence, a potential for failure of the foundation of the Category I BWST. (cent!';UI C" nEyr 7ASE)
~
- 6. IM'EDIATE RI?CFTABILIT! E7AII!AT:03: 7 ORGA'; ATION FIPCNSIEI.E FO? FUR;HF3
- a. O REPORTA3;E - GO TO 13 EVAI!UATIC:!: ,
- b. O POTEiTIE.LY FIPORTABLE - GO TO 13 Bechtel Engineering - Civil
- c. G N7: FIPCD3LE, FURSER EVALUATICN 6. FINE RI?CRIA3:LITY EVEUACC::
d.O NOT FIPCFTABLE (IT 6.c. CHICEED):
0F BLOCKS 1 TO 7:
W[
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MARAG:,.a - M?w,. YYk aA.:.
The first reanalysis ga'e displacement values which were inconsistent with measured settlement and anticipated values. This cast doubt upon the spring values used in the analysis. The subsequent finite element analysis gave displacement values which were con-sistent with the other values available for camparison, but gave for:es and moments which exceeded the FSAR allowables by an amount sufficient to warrant an additional check on these values also.
Two setiens planned to check these values are:
.. Retain a consultant to review tN res 21ts obtained by analyses done, ant 'ar do an independent check.
2 Excavate and inspect the foundati a for signs of overstressing (i.e., ,r nking).
It was considered premature to judge thb 4 reportable condition prior to con: nation of the values obta1 3 etf by the finite eleme ' snalysis. (CONTI2iUE CU 3 7 ? AGE)
- 11. EV.LUATOR'C 5 Y..ATURE/DA"'": .12. FINAL QA APPROV' - MA2:AGER :'FaA. CATE:
t /O j /-S~-dV i tyyf & 2l11I YI
- 13. NRC UCT!?ICATION: HOW? By Phene DATE: IT22/81 TIME: 1:30 FM INEI7IDUAI. NOTIFIED: Ray Sutphin & Ge .- iallagher
_l R-*'IRENCE: Telecen1/22/$1 Chren Fi *11175 2h
PROJECTS. E?! GIN E EPING c=== cAFETY L,ONCERN AND A= ca:rau==< -
)
P0wif OUALITY ASSURANCE DEPARTMENT QA70-0 REPORTABILITY EVALUATION SCRE NO: 5 PAGE 2
- k. CONTINUED 5 CONTINUED
- 10. CONTINUED
>=
- 14. MINI.WM DISTRISISION: 15. ADDITIO:AL DISTRIBUTION:
VIIF PRESIDENT - PE&C MPQAD - DQAE Supervisor V!OL PRE 3IDENT - MIDLAND PROJECT DI3'.COR - Eie"l!RONMENTAL SERVICES & Q;-
MZ:./JID SITE MANAGER '
SITI RA SUPERI::TENDENT g D !
f MXi;0ER - SAFETY & LICENSING ) p I M' E UD FILE :;3 15 1 0.h.9.h9 [Retricsmitted to distribution en 2/27/81 I I to show modification to Block 5 vording.
, (
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l
' Appendix A SeriCL 11510 i
ONSITE GEOTECHNICAL SOILS ENCINEER 023539 (backfill and laboratory testing)
POSITION DESCkIPTION:
S ummary:
Provides technical coordination and monitoring of onsite earthwork during construction. Explains specification requirements, and provides technical direction for addi-tional testing where necessary. Reports to the project soils engineer and quality control any detrimental or
( inadequate soils-related work. Documents all approvals, deficiencies, and resolutions, and all significant obser-vations or explanations.
Principal Responsibilities:
- 1. Excavation: Observe excavations to ensure that foun-
' dations and other facilities are constructed in accor-dance with applicable specifications and drawings. ,
- 2. Backfill: Observe backfill operations to ensure con-formance to specifications. .
- 3. Compaction Testing: Observe onsite testing operations to ensure the requirements of applicable specifications are met. Observe selected laboratory tests daily to ensure compliance with specifications. Review all testing reports and notify project soils engineer of any problems.
- 4. Soil Placement: Observe soil placement to ensure conformance to requirements of applicable specifica-tions.
- 5. Compaction Equipment: Observe soil placement to ensure that the compaction equipment is qualified and listed in the specification and can deliver the required ,
degree of compaction for the proposed backfill area.
Establish if the size of the backfill area is suffi-cient to enable checking the speed of advancement of compaction equipment. Advise quality control engineer of the in-place density testing frequency.
- 6. Inprocess Testing: Observe at least once a day the in-process field and laboratory testing operations. These testing operations shall inc1;4c density and moisture "
tests, gradation tests, and plasting zero air voids curves.
Appandix A
- 7. Specification Clarification: If clarification to the specification is required, request such clarifications in writing by mem randum r TWX. The clarifications 023539 will be furnished by project engineering by a specifi-cation change notice or by revising the specification.
- 8. Testing Frequency: Determine the size of the backfill location to establish the frequency of testing based on applicable specifications. These requirements are minimum. If additional tests are required, advise appropriate personnel and document such requests.
Ensure that soil placement is uniform and consistent.
- 9. Reworking Area Represented by Failing Tests: If a failing test is reported, review the calculations for errors. If the calculations are correct and the failing test is confirmed, advise appropriate personnel to rework the area represented by the failing test.
- 10. Test Fill Program: Observe soil placements to ensure that soil placement activities are compatible with those performed in the test fill program.
- 11. Reporting: Document in a daily report all significant observations, approvals, and deficiencies regarding soils-related work. Notify appropriate personnel of detrimental or inadequate work so that a resolution can be reached and rework and down-time minimized.
_ ,e- ,,- , - - - - ~~ ' ' ~ ' '