ML20140H095
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{{#Wiki_filter:. ( ( 5711 Summerset Drive Midland, MI 48640 April 2G,1982 T j Dr. Chester Sless, Acting Chairman Midland ACBS Subcommittee 3110 Newmark Laboratories 208 N. Romine University of Illinois Urbana, Illinois 01801
Dear Dr. Sless:
I am communicating with you in regard to the ACItS meeting that is being planned for April 29 in Washington, D.C. on the soil settlement problems at the Midland nuclear plant. As a citizen participant in the licensing proceedings since the construction license was first noticed I believe that I have some perspective on the problems I at the Midland nuclear plant that can be useful to the ACHS Subcommittee delib-
- erations, i
The soll settlement problem at Midland is one of many qunlity control problems that have plagued this plant since even before the construction permit was noticed for public hearing. The soll settlement problem, however, is per-t haps the most serious and most extensive of the many quality control problems at Midland, A summary of the soll settlement preliminary findings and the numerous j violations of 10CFR 50 Appendix B Quality Assurance that they represent can be I found on p 9 - 11, in NRC Stnff Testimony of Eugene J. Gallagher with Hespect to Quality Assurance Program Implementation prior to December 6,1979. (June 8,1981) (Enclosed) You are undoubtedly aware of the December 6,1979 Order in which the NRC asked for a halt on constru: tion of safety related buildings pending review of the action that Consumers had undertaken for the buildings that were settling at an abnormal rate at the site. } I would like to discuss some background events that have come up during the l soils hearings beyond what is set forth in the December 6,1979 Order. Fo/A-SS d ol-i 0510080444 850930 PDR FOIA D } c ef./* BRUNNER85-602 PDR D l3 ( . ~.
L Page Two Dr. Chester Siess April 20,1982 There are numerous examples of a pattern oflaxity toward PSAR/FSAR design recommendations throughout the construction site, and specifically in the construction buildings affected by the poorly compacted soll which this ACRC q Committee is considering. Not only is there evidence of poor communications, but deliberate withholding of significant information from the NRC is a part of the record. In 1977, evidence of soll settlement deficiencies was available to Consumers Power Co. and Bechtel, the construction engineer, prior to their beginning the construction of the diesel generator building. Consumers Power Co. makes the following admission in their recent Findings of Fact that this evidence "which if given different weight would have revealed the plant wide solls conditions in time to have prevented the problems which now confronts us". In addition, in 1978, information regarding the unusual settlement of the administration building in 1977 was withheld from the NBC. Today, Consumers Power Co. QA manage-ment still defends these incredibly irresponsible decisions. When unusual settlement of the administration building occurred in 1977, it was torn down, the soil was recompacted properly and the building rebuilt. The decision on safety related buildings, however, that were subsequently built on this poorly compacted soll was to preload the buildings with sand- "a fix" that Consumers admits was the least costly approach to try to solve the problem. This attempt at a cheap, quick "fix"is now the subject of these exten-sive soll settlement hearings. The NRC is requiring much more extensive remedial action. Because some of the poorly compacted sollis also under part of the dike of tha cooling pond, water has been seeping in throughout the plant site since the cooling pond was filled. While the original PSAR in 1909 included the provision of a permanent site dewatering plan, it was subsequently climinated without NBC concurrence, i llowever, because of the leakage from the cooling pond, an extensive dewatering system has been instituted. The NBC's DEIS states that the water from the dewatering system through-out the plant site will be pumped back into the cooling pond. I believe the question should be raised as to how this will effect the chemical content of the cooling pond water which must be carefully controlled for cooling the reactors, since the wastes, oil spills, and inevitable accidental radioactive spills on the plant site will un-doubtedly enter that dewatering system.
t b 2 i Page Threc Dr. Chester Siess i April 26,1982 i 1 i As further evidence of an indifferent attitude toward the PSAR/FSAR design, i it should be noted that in the mid-70's the foundations of the diesel generator build-ing and the borated water storage tanks were changed from the mot foundation plans without NRC concurrence. In 1981, the auxiliary building seismic analysis [ was found to be deficient. During NRC testimony in the soll settlement hearings,the FSAR has been referred to as merely a " historical document"instead of regarding it as a design commitment. Consumers has been allowed to initiate independently significant design modifications and has changed the FSAR after the fact to indicate how the plant was actually built. This amounts to building the plant first and then drawing up the blueprint. This practice can hardly assure this community and industry l here of safe construction of these plants. More recently, at the evidentiary hearing on February 2,1982,' Judges liarbour ) and Decker outlined their concerns about the QA program for the underpinning l structures (Tr 7122-28). As Judge liarbour pointed out, the underpinning activities themselves have the potential for producing irreversible damage in safety class structures or for altering the conditions of the structures on which seismic anal-i yses are based. l The fact that there are already indicaticns of inadequate quality assurance l performance in soils remedial areas has been described in the memo from H. L. Spessard to Darrell Eisenhut dated April 9,1982 Again, we find the problem of i misleading information and lack of adequate QA procedures. (copy enclosed) i l Recently, we invited researchers from the Government Accountability Project 1 (GAP) of the Institute of Policy Studies, Washington, D.C., to come to Midland to take testimony from workers at the Midland nuclear plant who have personal know-ledge of serious quality control violations on site--many of them occurring at the buildings that are under consideration at the April 29 meeting. The testimony from the workers was secured by Attorney Tom Devine of GAP and can be made available to you when we have it ready. l The GAP organization was successfulla finding numerous problems at the Zimmer nuclear plant which have required further NRC and ACBS action. Their l l findings at Midland are even more extensive than those at Zimmer. l I sincerely hope the ACRS deliberations will take into account the dismal, past i and continuing QA record at the Midland nuclear plants and particularly in those buildings affected by the soll settlement problems that will be the subject of dis-cussion on April 29. Yours sincerely, hMAA de Mary Sincla y l MS/jt cet om Devine, Government Accountability Project T 4
( O safety analysis report which had been submitted by Consumers <.as con-sistent with the design and construction of the Midland project. I 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 !!! office. These findings are docunented in Attachnent 4 In summary, the findings related to quality assarance deficiensies, are: The FSAR did not correctly state the type of fill material supporting safety related structures. This is a violation of 10 CFR 50 Appendis B quality assurance criterion !!!. (Design Control) ine FSAR included conflicting values for the settlement of the diesel generator building founded on spread footings. This is 3 f violation of 10 CFR 50 Appenoix B quality assurance criterion !!!. (De.signControl) Tne compaction requirement for clay raterial was not fol-lowed. Inis is a violation of 10 CFR 50 Appendix B quality assurance criterion V. (Instructions, Procedures and Drawings) The compaction requirement for sand was not correctly translated into the construction specifications. This is a violation of 10 CFR 50 Appendix B quality assurance criterion V. (Instructions. Procedures and Drawings) Moisture control was not properly implemented. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action) Soil was not protected from frost action nor removed prior to resuaing work. This is a violation of 10 CFR 50 Appendix B quality assurance criterion !!!. (Design Control) The root causes of nonconfoming conditions were not ade-Quately corrected to preclude repetition. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action) The settlement calculations for the diesel generator building were based on conditions of foundation type, load intensity and I l
1 \\ a t 'h soil compressibility other than the actual conditions. This is a violation of 10 CFR 50 Appencix B quality assurance criterion III. (Design Control) Consumers did not adequately investigate the extent of the soil problen af ter the settlement of the administration building footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action) Progran changes were not implemented to preclude erroneous ~ selection of the laboratory compaction standards (maxinun density and optimun moisture content) af ter the settlement of the administration building footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action) (We subsequently cetermine that the last two itens should not have been listed as quality assurance deficiencies because the adninis-tration building is not subject to quality assurance requirements.] Concrete raterial was pemitted to be used in lieu of fill material without consiceration of tne effects on structures. This is a violation of 10 CFR 50 Aspen:ix 3 cuality assuran:e criterion V. (Instructions Procedures and 3raaings) Personnel directing the soils ooeration were not trained in tne area of soil work, nor was a geotechnical soils engineer present on-site as required. Inis is a violation of 10 CFR 50 Appendix B ouality assurance criterion II. (Quality Assurance program) Inspection procedures were relaxed fron original procedural requirenents 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 inado-quate to verify conforrance. Tnis is a violation cf 10 CFR 50 Appendix 3 quality assurance criterion X. (!nspection) Based on the above findings it was my conclusion and it is my conclusion now that: (1) There was inadequate control and supervision of tne plant fill. (2) Corrective action regarding nonconformances was inadequate. (3) Construction specifications and design bases were not followed, (4) Interface between design organization and construction was inadequate. (5) The FSAP contqined inconsittcnt, incorrect and uncupported stateinents. (copied from page 11)
m..._ ^ i 7 ( ( ,.m ,i 5711 Summerset Drive t ) Midland, MI 48640 i April 26,1982 i t ? Dr. Chester Sless, Acting Chairman Midland ACHS Subcommittee i 3110 Newmark Laboratories 208 N. Romine + University of Illinois Urbana, Illinois 61801
Dear Dr. Sless:
j i am communicating with you in regard to the ACRS meeting that is being planned for April 29 in Washington, D.C. on the soll settlement problems at the Midland nuclear plant. I As a citizen participant in the licensing proceedings since the construction j license was first noticed, I believe that I have some perspective on the problems at the Midland nuclear plant that can be useful to the ACHS Subcommittee delib-erations. The soll settlement problem at Midland is one of many quality control problems that have plagued this plant since even before the construction permit 4 l was noticed for public hearing. The soll settlement problem, however, is per- ] haps the most serious and most extensive of the many quality control problems at Midland. i l A summary of the soil settlement preliminary findings and the numerous j violations of 10CFR 50 Appendix B Quality Assurance that they represent can be l found on p 9 - 11, in HIC Stnff Testimony of Eugene J. Galingher with Respect to Quality Assurance Program implementation prior to December 6,1979. ) (June 8,1981) (Enclosed) l You are undoubtedly aware of the December 6,1979 Order in which the NHC asked for a halt on construction of safety related buildings pending review of the action that Consumers had undertaken for the buildings that were settling at an abnormal rate at the site. l I would like to discuss some background events that have come up during the soils hearings beyond what is set forth In the December 6,1970 Order. 1
i ( ( Page Two Dr. Chester Siess April 26,1982 There are numerous examples of a pattern of laxity toward PSAH/FSAR design recommendations throughout the construction site, and specifically in the construction buildings affected by the poorly compacted soll which this ACRC Committee is considering. Not only is there evidence of poor communications, but deliberate withholding of significant information from the NHC is a part of the record. In 1977, evidence of soil settlement deficiencies was available to Consumers Power Co. and Bechtel, the construction engineer, prior to their beginning the construction of the diesel generator building. Consumers Power Co. mal es the following admission in their recent Findings of Fact that this evidence "which if given different weight would have revealed the plant wide soils conditions in time to have prevented the problems which now confronts us". In addition, in 1978, information regarding the unusual settlement of the administration build!ng in 1977 was withhcid from the NHC Today, Consumers Power Co. QA manage-i ment still defends these incredibly irresponsible decisions, j When unusual settlement of the administration building occurred in 1977, it was torn down, the soil was recompacted properly and the building rebuilt. I The deelston on safety related buildings, however, that were subsequently built on this poorly compacted soll was to preload the buildings with sand- "a fix" that Consumers admits was the least costly approach to try to solve the i problem. This attempt at a cheap, quick "fix"is now the subject of these exten-sive soll settlement hearings. The NHC le requiring much more extensive remedial action. i Because some of the paorly compacted sollis also under part of the dike of the cooling pond, water has been sceping in throughout the plant site since the cooling pond was filled. While the original PSAR in 1909 included the provision of a permanent site dewatering plan, it was subsequently climinated without NHC concurrence. l Ilowever, because of the leakage from the cooling pond, an extensive dewatering system has been instituted. The NHC's DEIS states that the water from the dewatering system through-out the plant site will be pumped back into the cooling pond. I believe the question should be raised as to how this will effect the chemical content of the cooling pond water which must be carefully controlled for cooling the reactors, since the wastes, oil spills, and inevitable accidental radioactive spills on the plant site will un-doubtedly enter that dewatering system. l l 1 i l
~ (f ( t Page Three Dr. Chester Sless y i April 26,1982 a 4 As further evidence of an indifferent attitude toward the PSAR/FSAR design, i it should be noted that in the mid-70's the foundations of the diesel generator build-ing and the borated water storage tanks were changed from the mot foundation plans without NRC concurrence. In 1981, the auxiliary building seismic analysis was found to be deficient. During NRC testimony in the soll settlement hearings,the FSAR has been referred to as merely a " historical document"instead of regarding it as a design commitment. Consumers has been allowed to initiate independently significant design modifications and has changed the FSAR after the fact to indicate how the j plant was actually built. This amounts to building the plant first and then drawing up the blueprint. This practice can hardly assure this community and industry here of safe construction of these plants. I More recently, at the evidentiary hearing on February 2,1982, Judges liarbour and Decker outlined their concerns about the QA program for the underpinning structures (Tr 7122-28). As Judge liarbour pointed out, the underpinning activities themselves have the potential for producing irreversible damage in safety class j structures or for altering the conditions of the structures on which scismic anal- ] yses are based. The fact that there are al cady indications of inadequate quality assurance performance in soils remed! 41 areas has been described in the memo from 11. L. Spessard to Darrell Eisenht.' dated April D,1982 Again, we find the problem of 1 j misleading information and lack of adequate QA procedures. (copy enclosed) Recently, we invited researchers from the Government Accountability Project (GAP) of the Institute of Policy Studies, Washington, D.C., to come to Midlend to 4 take testimony from workers at the Midland nuclear plant who have personal know-i ledge of serious quality control violations on site--many of them occurring at the buildings that are under consideration at the April 29 meeting. The testimony i from the workers was secured by Attorney Tom Devine of GAP and can be made available to you when we have it ready. I The GAP organization was successful in finding numerous problems at the Zimmer nuclear plant which have required further NRC and ACHS action. Their i findings at Midland are byen more extensive than those at Zimmer. I sincerely hope the ACHS deliberations will take into account the dismal, past ) and continuing QA record at the Midland nuclear plants and particularly in those buildings affected by the soll settlement problems that will be the subject of dis-cussion on April 29. 4 ,g Aw EU^d-Mary Sincla[ MS/jt 1 cc: Tom Devine, Government Accountability Project - - - ~ -..--. ~.
( ( safety analysis report whic'1 had been submitted by Consumers..as con-sistent with the design and construction of the Midland project. Q. 12. Summari:e your preliminary investigation findings. A su=ary of the preliminary investigation findings were pre-sented to Consumers on February C3,1979 at the Region !!! office. These findings are docurented in Attachrent 4 In sur.rary, the findings related to quality a$$Jrance deficiencies, are: The F5AR did not correctly state the type of fill material supportin; safety related structures. This is a violation of 10 CFR 50 Accend1x 3 quality assurance criterion III. (Design Control) Ine F5AR included conflicting values for the settle-ent of the diesel generator builoing founced on spread footings. This is a f vielation of 10 CFR 50 Appencix 3 quality assurance criterion I!!. (De. sign Control) Tne compa: tion require ent for clay raterial was not fol-loaed. Inis is a violaticn of lu CFR 50 Appencix B quality assurance criterion V. (Instructions, Procedures and Drawings) The compaction requirement for sand was not correctly translated into the construction specifications. This is a violation of 10 CFR 50 Appendix 5 cuality assarance criterion V. (Instructions, Procedures and Drawings) Moisture control was not properly imple ented. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action) Soil was not protected from frost action nor renoved prior to resuaing work. This is a violation of 10 CFR 50 Appendix B quality assurance criterion !!! (Design Control) The root causes of nonconforning conditions were not ade-ouately corrected to preclude repetition. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action) The settlement calculations for the diesel generator building were based on conditions of foundation type, load intensity and -I
1 7 l.', q ( s
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[ ! } soil compressibility other than the actual conditions. This is a l violation of 10 CFR 50 Appendix B quality assurance criterion !!!. 4 (Design Control) j Consumers did not adequatt.ly investigate the extent of the / soil problem af ter the settlement of the administration building 3 footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterionXVI.(CorrectiveAction) 4 2 Program changes were not implemented to preclude erroneous . selection of the laboratory compaction standards (maximum density and i optimum moisture content) af ter the settlement of tne administration i building footings. This is a violation of 10 CFR 50 Appendix B quality [ assurance criterion XVI. (Correcti.e Action) ) [We subsequently deternined that the last two items should not j have been listed as quality assurance deficiencies because the adminis-l trationbuildingisnotsubjecttoqualityassurancerequirements.] 2 Concrete material was permitted to be used in lieu of fill material without consiceration of the effects on structures. This is a j violation of 10 CFR 50 Aopendix 3 cuality assurance criterion V. (Instructions, procedures anc Drawings) i personnel cirecting the soils operation were not trained in l the area of soil work, nor was a geotechnical soils engineer present j on-site as required. Tnis is a violation of 10 CFR 50 Appendix B oualit/ I assurance criterion !!. (Quality Assurance program) \\ l Inspection procedures were relaxed from original procedural l 1 requirenents which provided insufficient hold points to ascertain back-j j fill material was installed properly. This is a violation of 10 CFR 50 Appendix B quality assurance criterion X. (Inspection) ine sampling (surveillance) plan was infrequent and insdo-quate to verify conformance. This is a violation of 10 CFR 50 Appendix B l quality assurance criterion X. (Inspection) I Based on the above findings it was my conclusion and it is my i conclusion now that: i j (1) There was inadequate control and supervision of the plant fill. (2) Corrective action regarding nonconformances was inadequate. 1 l (3) Construction specifications and design bases were not followed, d (4) Interface between design organization and construction was i inadequate. (5) The FSAP contmined inconulstent, incorrect and uncupported statuinents. I (copied from page 11) i l
e 5711 Summerset Drive Midland, MI 48640 April 26,1982 1 Dr. Chester Siess, Acting Chairman Midland ACBS Subcommittee 3110 Newmark Laboratories 208 N. Romine University of Illinois Urbana, Illinois 61601
Dear Dr. Sless:
I am communicating with you in regard to the ACRS meeting that is being planned for April 29 in Washington, D.C. on the soll settlement problems at the Midland nuclear plant. As a citizen participant in the licensing proceedings since the construction license was first noticed, I believe that I have some perspective on the problems at the Midland nuclear pinnt that can be useful to the ACRS Subcommittee dellb-erations. The soil settlement prcblem at Midland is one of many quality control problems that have plagued this plant since even before the construction permit was noticed for public hearing. The soil settlement problem, however, is per-haps the most serious and most extensive of the many quality control problems at Midland. A summary of the soil settlement preliminary findings and the numerous i violations of 10CFB 50 Appendix B Quality Assurance that they represent can be ( found on p 9 - 11, in h*RC Staff Testimony of Eugene J. Galingher with Respect to Quality Assurance Program implementation prior to December 6,1979. (June 8,1981) (Erclosed) You are undoubtedly aware of the December 6,1979 Order in which the NRC asked for a halt on constru: tion of safety related buildings pending review of the action that Consumers had undertaken for the buildings that were settling at an abnormal rate at the site, I would like to discuss some background events that have come up during the soils hearings beyond what is set forth in the December 6,1979 Order. l l
o. 4? i Pa;e Two Dr. Chester Siess April 2G,1982 i There are numerous examples of a pattern of laxity toward PSAR/FSAR design recommendations throughout the construction site, and specifically in the construction buildings affected by the poorly compacted soll which this ACRC Committee is considering. Not only is there evidence of poor communications, i but deliberate withholding of significant information from the NBC is a part of the record. l 4 In 1977, evidence of soll settlement deficiencies was available to Consumers Power Co. and Bechtel, the construction engineer, prior to their beginning the 4 i construction of the diesel generator building. Consumers Power Co. makes the following admission in their recent Findings of Fact that this evidence "which if j given different v alght would have revealed the plant wide soils conditions in time i to have prevented the problems which now confronts us". In addition, in 1978, information regarding the unusual settlement of the administration building in 1977 was withheld from the NRC. Today, Consumers Power Co. QA manage-ment still defends these incredibly irresponsible decisions. 4 When unusual settlement of the administration building occurred in 1977, it ~ was torn down, the soll was recompacted properly and the building rebuilt. The decision on safety related buildings, however, that were subsequently built on this poorly compacted soll was to preload the buildings with sand- "a j fix" that Consumers admits was the least costly approach to try to solve the problem. This attempt at a cheap, quick "fix"is now the subject of these exten-sive soll settlement hearings. The NRC is requiring much more extensive remedial action, i l Because some of the poorly compacted sollis also under part of the dike of the cooling pond, water has been seeping in throughout the plant site since the j cooling pond was filled. I While the original PSAR in 19G9 included the provision of a permanent site 1 dewstering plan, it was subsequently eliminated without NRC concurrence. l However, because of the leakage from the cooling pond, en extensive dewatering system has been instituted. The NRC's DEIS states that the water from the dewatering system through-out the plant site will be pumped bpek into the cooling pond. I believe the question should be rotsed as to how this will effect the chemical content of the cooling pond water which must be carefully controlled for cooling the reactors, since the westes, { oil spills, and inevitable accidental radioactive spills on the plant site will un-doubtedly enter that dewatering system. )
Page Three Dr. Chester Sless April 26, !!'S2 As further evidence of an indifferent attitude toward the PSAR/FSAR design, it should be noted that in the mid-70's the foundations of the diesel generator build-ing and the borated water storage tanks were changed from the mat foundation plans without NRC concurrence. In 1981, the auxiliary building seismic analysis was found to be deficient. During NRC testimony in the soll settlement hearings,the FSAR has been referred to as merely a " historical document"instead of regarding it as a design commitment. Consumers has been allowed to initiate independently significant design modifications and has changed the FSAR after the fact to indicate how the plant was actually built. This amounts to building the plant first and then drawing up the blueprint. This practice can hardly assure this community and industry here of safe construction of these plants. More recently, at the evidentiary hearing on February 2,1982, Judges liarbour and Decker outlined their concerns about the QA program for the underpinning structures (Tr 7122-25). As Judge liarbour pointed out, the underpinning activities themselves have the potential for producing irreversible damage in safety class structures or for altering the conditions of the structures on which seismic anal-yses are based. The fact that there are already indications ofinadequate quality assurance performance in soils remedial areas has been described in the memo from R. L. Spessard to Darrell Eisenhut dated April D,1982 Again, we find the problem of misleading information and lack of adequate QA procedures. (copy enclosed) Recently, we invited researchers from the Government Accountability Project (GAP) of the Institute of Policy Studies, Washington, D.C., to come to Midland to take testimony from workers at the Midland nuclear plant who have personal know-ledge of serious quality control violations on site--many of them occurring at the buildings that are under consideration at the April 29 meeting. The testimony from the workers was secured by Attorney Tom Devine of GAP and can be made available to you when we have it ready. The GAP organization was successfulin finding numerous problems at the Zimmer nuclear plant which have required further NRC and ACRS action. Their findings at Midland are even more extensive than those at Zimmer. I sincerely hope the ACRS deliberations will take into account the dismal, past and continuing QA record at the Midland nuclear plants and particularly in those buildings affected by the so!! settlement problems that will be the subject of dis-cussion on April 29. Y rs si m e h Mary Sincle[ hE4A 4+ v'- MS/jt cc Tom Devine, Government Accountability Project
3_._ f t 9 I D safety analysis report which had been submitted by Consumers.as con-sistent with the design and construction of the Midland project. l
- 0. 12. Sum.narize your preliminary investigation findings.
A summary :f the cre11cinary investigation findings were pre-sente: to Consa.ers On Fetesary 23, 1979 at the Re;fon !!! office. These fincings are docs ented in Attachment 4 In sum.aay, the findings 1 j related to quality asssrance deficiencies, are: j The FSAE cia not correctly state tne tyce of fill material saooortin; safetj relate: structares. This is a violation of 10 CFR 50 -;;en:ts 5 cuality asss acce criterion !!I. (Design Control) r 1 i T*.e FSA: in:1uded c:rflicting values for the settle'en* of j the ciesei geaerator ts*1cir fcan:e: on sprea: footings. Tnis is a i [*'N vieletion o' 10 CFR 50 ;oen;:in 5 cuality assurance criterion ::!. (DesignControl) 1 Ine :: ;a:ti:n re;uire er.: fer clay raterial was not fol-lo-ec. Ints is a violat :n of 10 CFR 50 Appen:1x 5 quality assurance d criterion V. (Iastau:tiens Fro:edures an: Drawings) The co ca:tio*. re:vice.ent for sand was not correctly translate into the constra:ti:n specifications. This is a violation of 10 lFr. 53 Ap;er.:ix 5 coality ass.rance criterion V. ( nstru:tions, Procedures and Drawings) Motsture ::nte:1 was not properly icple ented. Inis is a violation of 10 CFR 50 A;;endix B ouality assurance :riterion XVI. (Correc.tive Action) Soil was n:t protecte: fron frost a: tion nor removed prior to resuaing work. Tnis is a violation of 10 ;FR 53 Appendix B quality assurance criterion !!l. (Design Control) The root causes of nonconforming conditions were not ace-oustely corrected to precluoe recetition. This is a violation of 10 CFR 50 Appendix B quality assurance c&iterion XVI. (Corrective Action) The settlement calculations for the diesel generator
==g building were based on conditions of foundation type, load intensity and 1 I i _ ~ _.... _ _.
I
- p.
soil compressibility othea than the actual conditions. This is a violation of 10 CFR 50 Appencix B quality assurance criterion !!!. (Design Control) Consumers did not adequately investigate the extent of the i soil problem after the settienent of the administration building footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (C:rrective Action) Progran changes were not implemented to preclude erroneous selection of the laboratory ccmpaction standards (maximum density and optimum ncisture content) af ter the settlement of tne administration building footings. This is a violation of 10 CFR 50 Appendix 8 quality assurance criterion XVI. (Ccerective Action) (Wesubsequentlyceternine: that the last two itens should not have been listed as ;uality assurance deficiencies because the ac.inis-tration building is not su: ject to quality assurance re;uirenents.] Concrete material was per-itted to be usec in lieu of fill caterial withcut censiceration cf tne effects on structures. This is a violation of 10 CF; iC A pencix 3 cuality assurance criterion ". (Instruct 10ns, procecares and Ora ings) r Persennel cirecting the soils operation were not traine in the area of soil work, nor was a geotechnical soils engineer present on-site as required. Inis is a violation of 10 CFR 50 Appendte B cuality asssrance criterien !!. (Ouality Assurance program) Inspection proce: ares were relaxe: fro original procedural reasirenents which provice: insufficient hele peints to ascertain back-fill material was installe: preserly. This is a violation of 10 CFR 50 Appendix B quality ass.rance criterien X. (Inspection) The sampling (surveillance) pian was infrequent and inade-quate to verify c:nformance. Tnis is a violation cf 10 CFR 50 Appencix 9 quality assurance criterion X. (Inspection) Based on the above findings it was my conclusion and it is.my conclusion now that: (1) Tnere was inacequate control and supervision of the plant fill. (2) Corrective action regarding nonconferrances was inade;uate. (3) Construction specifications and design bases were not followed. (4) Interface between design organization and construction was inadequate. (5) The FSAP contnined inconsittent, incorrect and unsupported statements. (copied from page 11)
( c DOClMENTS StfMARIZING THE SOILS-RELATED ISSUES AT MIDLAND 1. Sunnary of Soils-Related Issues at the Midland Nuclear Plant. 2. Selected Consumers Power Company submittals related to Midland's Auxiliary Building and Feedwater Isolation Valve Pit. 3. Selected Consumers Power Company submittals related to Midland's Borated Water Storage Tank. 4. Selected Consumers Power Company submittals related to Midland's Diesel Generator Building. 5. Selected Consumers Power Company submittals related to Midland's Permenant Plant Dewatering. 6. Selected Consumers Power Company submittals related to Midland's Service Water Pump Structure. 7. Selected Consumers Power Company submittals related to Midland's Underground Utilities. 8. Selected NRC Documents Related to Midland's Soils and Structural Settlement Issues. ATTACMENT 5
U [$ ( %Q ', .= .. !E CHFOSOLO;Y REGARDI'iG DLA*iT FILt ~; F:CIEhCIES ~ M/~7/78 Applicant's ve-bal report to Rep on 111 of abnor al settlenent of Diesel Generator Building (DGB) 09,*29/78 First 50.55(e) interim report on'DGB settlerent issued 11/01/7S Region III ' requests hRR review support on soils corpaction a dequacy 11/07/78 Second 50.55(e) interim report on DBG settlerent issued 11/24-27/78 Investigation by Region III on DBG settlement' documented by inspection report 50-329/78-12; 50-330/78-12 12/03-04/78 Meeting and site tour on DGB settlement 12/14/78-Special Prehearing Conference on OL issues 12/21/78 Third 50.55(e) interim report on DGB settlement issued 12/21/78 50.55(e) notification that applicant has selected.preload as corrective action for DGB 01/05/79 Supplement to third 50.55(e) interim report on DGB settlement 01/25/79 Start of surcharge placement for DGB 02/23/79 OL Prehearing Conference Order - accepts W. Marshall contention 2 and M. Sinclair contention 24 on soils 02/23/79 Meeting with Region III on soils QA 02/23/79 Fourth 50.55(o) interim report on DGB settlement ~ 03/05/79 ' Meeting with Region III and NRR on Region III investigation 03/06/79 Site visit 03/21/79 Staff issues first set of 50.54(f) questions regarding' plant fill (Questions 1-22) 03/22/79 Region III issues investigation report on soils 50-329/78-20; 50-330/78-20 03/28/79 Accident occurs at Three Kile Island, Unit 2 i ~ /'04/24/79 Applicant's initial response to 50.54(f) requests regarding plant fill 04/30/79 Revision 5 to 50.55(e) interim report on DGB settleme'nt l a
( ',. ~ (' e 2
- t.TE CRGMLOGY REGARDING PLANT FILL DEFICIE'CIES u
05/31f79 Revision 1 to Applicant's resonse to 50.54(f) requests regarding plant fill 06/07/79 ' Site visit by staff to observe test pits in plant fill j 06/25/79, Revision 6 to 50.55(e) interim report on DGB settlement 07/09/79 Revision 2 to Applicant's response to 50.54(f) requests regarding plant fill /07/18/79 Meeting on results of DGB preload program, site investiga-tion, proposed fixes including caissons, underpinning and dewat.ering (Summary: Applicant's 50.54(e) report dated August 10,1979) 07/19/79 Meeting on site geology 09/05/79 Revision 7 to 50.55(e) interim report on DGB settlement coils 09/05/79 Meeting on draf t 50.54(f) question 23 regarding mils QA l solis 09/11/79 Staff issues 50.54(f) question 23 regarding e.54e QA /09/13/79 Revision 3 to response to 50.54(f) request regarding plant 5 fill / 10/16/79 Staff announces that U.S. Arg Corps of Engineering to assist with geotechnical engineering review 11/02/79 Revision 8 to 50.55(e) interim report on DGB sett1'ement [11/13/79 Revision 4 to response to 50.54(f) requests regarding plant fill 11/14/79 Initial site visit by Corps of Engineering 11/19/79 Staff issues supplement'al 50.54(f) questions 24-35 12/b6/79 NRC issues order requiring modification of co'nstruction permits prior to proceeding with soils remedial activities 12/19/79 Applicant files Amendment 72 requesting modifications of CP's and requesting staff approval of proposed soils remedial A
- ctivities 12/25/79 Applicant requests hearing on NRC's 12/06/79 'ordei-i
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.r CH:.0NOLOGY REGARDING PLANT FILL DEFICIENCES ~ 01/16/80 Meeting on 50.54(f) responses and proposed remedial activities on plant fill (Suncary issued 02/04/80) 02/07/80 Appli$'s notice of termination of 50.55(e) reporting on DGB Settlement 02/11/80 Submittal of documents referenced by A.endment 72 02/26/80 NRC announces that Naval Surface Weapons Center to assirt in structural engineering review 02/27-28/80 Meeting and site tour regarding plant fill deficiences and remedial actions 02/28/80 Revision 5 to responses .54(f) requests. regarding plant fill 02/29/80 NRC announces that Energy Technology Engineering Center to assist in gechnanical Engineering review 04/01/80 Staff requests additional reports, drawings and other infor-mation on plant fill deficiencies and fixes 06/30/80 Staff requests additional soils exploration, sampling, and laboratory tests (Questions 36-38) I-- 07/07/80 Staff provides guidelines for future audit on seismic and structural design calculations 9 07/31/80 Meeting to discuss soils remedial actions and staff request for additional bcrings and tests ~ f 08/04/80 Staff letter forwarded Corgs of Engineering request for infor-mationandsoils. testing (Questiosn39-48) 08/27/80 Staff requests information on site dewatering (Questions 49-53) 08/28/80 Site tour for NRC management and consultants 08/29/80 Meeting to hear applicant's appeal of staff request "for addi- ~ tional borings and tests (Question 37) 10/07/80 - Oral depositions of staff, applicant, Bechtel and consultants " C ~E^. during discovery for soils (OM, OL) hearing f e 9 k 7.. e
( .( MME CHROWLO3Y 2.ESAD. DING PLANT FILL DEF10!Ef. IES L 10/14/80 Staff position letter providing acceptable alternatives for determining seismic input t 10/20/80 ' Staff letter expressing concerns for underground piping stressess .:s* o-rr:a 4 * ^ 11/10/80' . Staff letter denying applicant's appeal.!at staff request' for additional soils exploration, sampling and lab tests 11/14/80 Applicant replies to underground pipe stress concerns 11/21/80 Amendment 85 submitted responding to Questions 39-44, 46-53 11/24/80 Meeting on systematic appraisal of licensee performance (SALP) 01/27/81 Site visit to observe BWST concrete foundation cracking 01/28-29/81 Special Prehearing Conference on plant fill issues '02/20/81 50.55(e) report 81-03 on cracking in BWST foundations (sub-sequent interim reports issued 4/3/81, 6/12/81, 6/26/81, 7/21/81, 8/28/81, 10/26/81, 11/13/81, 11/24/81, 12/11/81, and1/18/82) 7 3i .03/02/81 Parts I and III of applicant's report on site specific response spectra ~ 03/23/81 Applicant's letter announcing underpinning of service water pump structure will be based upon a perimeter wall concept, rather than piles 'i 04/20-24/81 Design audit of seismic Category I structures and seismic calculations (Sumary issued March 2,1982) 04/27/81 Special Prehearing Conference on plant fill issues b5/05-07/81 Meeting on Underground pipes, Amendment 85, solid pier concept [' for Auxiliary Building underpinning, and Borated Water Storage k' Tank foundations 05/13/81 Part II report by applicant on site specific response spectra . f 06/17/81 Addendum to Part I report on site specific response spectra (original ground surface) e O e g
c. UI ' 'Y .jfy-On,b ht:O scg e* ~ CHRCNOLOGY REGA.;DI'$ PLANT FILL OEFICIEroCIES
- E 06/19/81 Prelimir.ary results of soils boring and testing program for cooling pond dikes g
L--- 06/33/S1 Meeting on seismic margin review criteria 07/15/81 Telephone conference discussion on BWST surcharge (Suw.ary issued July 29,1981) 07/27/81 Report on final results of soil boring and testing program for perimeter and baffle dike area 07/27/81 Transmittal of update of site settlement measurements and piezometer data 08/04-13/81 OM, OL hearing on Stamiris' contentions _ 08/11/81 Applicant's report on basis for rejection of 1966 Parkfield Earthquake Accelerograms for site specific response spectra ' -- d 08/26/81 Transmittal of technical report and drawings on SWPS under-pinning g ~ 09/08/81 Meeting on seismic input pjframeters v 09/11/81 Applicants 1etter with updated settlement plots for several ,,,,4,. structures on fill L. 09/16/81 Meeting on site specific response spectra --~ 2 09/17/81 Meeting on SWPS remedial actions (Sur.ary 11/23/81) / 09/22/81 Transmittal of Part I of report on soil borings and tests . Eor Auxiliary Building 4 09/24/81 Telephone conversation in which staff requests additional information on soil concerns for Diesel Generator Building 09/25/81 Staff concurrence on surcharging valve pits for BWSTs 09/25/81 Transmittal of applicant's proposed seismic margin review criteria 09/30/81 Transmittal of technical report and drawings on Auxiliary Building and dynamic models for Auxiliary Building and SWPS O O e e
e .. Q (_ ( _g_ f.. CHR0iOLOGY REGARDING PLA'iT FILL DEFICIEf;CIES DATE 09/30/81 Meeting on DGB soil borings and testing results 10/01/81 Meeting on Auxiliary Building underpinning (Surmary 2/5/82) i - 10/02/81 ' Meeting on seismic models for Auxiliary Building and SWPS (Summary 1/25/82) I 10/02/81' Transmittal of DGB concrete crack analysis 10/06-07/81 Meeting on underground pipes and DGB settlement measurements (Two summaries issued 2/5/82) 10/13-16/81 Hearing on seismic issues N..' /. 10/19/81 Respo'nses to open items from structural design audit of April 20-24,1981 / 10/21/81 Applicant's letter responding to verbal requests of 9/24/81 -?:- ~ regarding DGB 10/26/81 Parts 1 and 2 of Woodward-Clyde report " Test Results. Auxiliary Building, Soil Boring and Testing Program" 10/26/81 Amendment 97 (Revision 12 to Responses to NRC Requests Regarding Plant Fill and settlement update report) .10/28/61 BWSTs filled with water ~ 3, ". M 10/28/81 Request for staff concurrence for construction of access shakh and freezewall in preparation for underpinning of. Auxiliary-Building 10/30/81 Telephone conversation in which staff requests additional infor-mation on remedial action for Auxiliary Building j ~ 11/04/81 Mpeting on Auxiliary Building and response to October 30 requests (s ~ 1 mM st 13*ho) 11/06/81 Response to staff reque'sts on Sept. 17, 1981, on SWPS underpin-p... - ning 11/06/81 Test liesults of soil boring and testing for SWPS y - 11/10/81 Transmittal of results of soil borings and tests for BWSTs' , 11/12/81 Meeting on soils remedial action schedules (s n V ilJu)&l) j I v w --.. y s, .-e-- --4.--,.
. ( V 7, OATE CHRC.0L33Y REGAD.31! G PLANT FILL DEFIC ENCIES
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\\ / ~ 11/13/81 " Design Report for the BWST Foundation Analysis" 11/16/81 Transmittal of letter " Response to NRC Request for Additional' Ir.for..ation Pertaining to the Proposed Underpinning of the Auxiliary Building and FW1V Pits". Includes alteration to the FWIy? underpinning configuration Y 11/17/81 Meeting on construction schedules for remedial underpinning for Auxiliary Building & SWPS 4 11/24/81 Staff concurrence for construction of vertical access shafts and freeze. wall in preparation for underpinning the Auxiliary Building and Feedwater Isolation Valve Pits 11/.24/81 Staff visit to observe underpinning of structures neat the Philadelphia subway tunnel j, p.u I 11/24/81 Transmittal of results (Part II of Woodward-Clyde report) of ' soil boring and testing program for Auxiliary Building 11[24'/81 Staff given copy of report " Seismic Safety Margin Evaluation Workshop" (Summary March 16, 1982) BWST/oundationOL Design Report for the BWSi,D'esign.C'alculations plus enclosure 1 11/24/81 Foundation Analysis *(55(e) Report 81-03 #9) ~ 12/01-04/81 Hearing - Auxiliary Building Underpinning '12/03/81 Underpinning of the Auxiliary Building - Calculational Resu1Ys' (supplements September 30, 1981, letter) 12/10/81 Meeting on [ racks in Auxiliary Building, SWPS & DGB
- ^/14-18/81 Hearing on' Seismi.c M$dels and SALP and QA drganization 12 e
gb. r.,,,ietter on Underground /ipe with several related encl y J 12/15/81 6 'l l2/30/81 Staff issues proposed findings of fact and conclusions of. law (QA) '. 01/04/82 Staff receives advanced copy of Applicant's draft. Testimony (12/31/81) on Service Water Pump Structure 01/06/82 Applicant's letter on effects of Auxiliary Building {' reeze. Wall on Utilities and Structures O e
(' 8 ( DATE CHR00LOSY REGARDING PLANT FILL DEFICIENCIES r 01/07/82 General Quality Plan for Underpinning & Quality Plans and Q-list activities for SWPS and Auxiliary Building ynderpinning 01/11/82 Meeting on Cracks (Sumary March 16, 1982) 01/12/82 Meeting in Glen Ellen on QA 0rganization change and General g Quality Plan on Underpinning (Sumary January 29, 1982) 01/13/82 Meeting on BWST (Sumary February 8,1982) j. L 01/18/82 BWST Foundation 07 Design Calculations including SKA report on tank stresses '(sarne letter also dated January 11,1982) / 01/18-19/82 Audi t, eting rior to. Excavation beneath FIVP & TB (Phase II k jf~. y,.i,.y,s of nd rpinni Constru'ction) (Sumaries March 10,1982, and Ma h 16, 1982)") ~~' 01/20/82 _ a gg.fr Meeting on Freeze Wall effects (Ann Arbor) (Sumaries March 10.,', 7 16, 19k2)g k bl/21-22/82 Meeting on Underground P'ipes V t' 01/25/82 Applicant's letter - Evaluation Report for the FIVPs 01/26/82 Applicant's letter - Quality Assurance, rganization change 1-Telecon discussion n surcharge results for BWST foundations [ D .D1/26/8.2 . L. Applicant's letter to ASLB on QA frganization (1/26/82. letter)-~.$ .e - 01/28/82 and Kudit reports regarding qualifications of Bechtel electricaT g inspect ka. 01/29/82 Evaluation eport for Auxiliary Buidling Control Tower & EP Areas on cracks 02/02/82 Hearing on QA 0rganizational change Auxiliary Building Crac[ksxcavation B'eneath Auxiliary 07/02-05/82 Audit meeting prior to 02/04/82 Applicant's letter on Augering niethod for soldier pile holes for access shaft of the Auxiliary Building 02/16/82 Applicant's letter with enclosure on Evaluation, Report for con-s crete cracks in the Diesel Generator Building e e e e e
,( -( 9 DATE CHRONOLO3Y REGARDIliG PLA'<T N LL DEFICIEtiCIES .~ ~ 02/16-15/82 Hearing on SWST and l'ndergrour.d Pipe v/ - 02/23-26/82 Meetings on DGB, SWDS, BWST. Surcharge Removal, Dewatering td , Recharge ligt results (17 days of data') and, Additional )12 settle-bents for Auxiliary Building '<onitoring (Sun ary March 'l - 02/25/82 Staff receives advanced copy of Applicant's draft testimony (1-8-82) on structural reanalysis of DGB, excluding Appendix C / - 02/26/82 Staff letter of concurrence for removal of surcharge from BWST valve pits '.~ - 03/02/82, Applicarlt's letter with report responding to request for pddi-tional information " Service Water Pump Structure Three-Dimensional Finite-Element Models" SWPS Technical Report dated 8/25/81)(This is an appendix to 03/02/82 Applicant's letter with report " Evaluation of Cracking 1.n Service Water Pump Structure at Midland Plant" 03/03/82 Meeting on dewatering Criteria (Summary March 16, 1982)' 3 04/82 Meeting on hearing schedules i 03/10/82 Applicant's letter on settlement of J ndergroundfiesel, Fuel oil Jankw due to Seismic Shakedown V 5 V 03/1D/82 Applicant's letter on protection of excavation face for the , y[.{ Auxiliary Building underpinning access shaft M 03/10/82 Meeting on QA for underpinning (Summary March 12, l982) - 03/12/82 NRC notified of loose sands beneath SW piping (Summary March 16, 1982) i 03/16/82 Meeting with Director, NRR on schedules - 03/16/82 Applicant's lett'er providing additional information on hied piping, with enclosures on future monitoring program and. replace-ment of 26" and 36" SW piping 03/16-19/82 Audit on SNS tlnderpinning ' V 3 03/18/82 Applicant's letter regarding surcharge removal for the JWST valve pits 9 -,-~,e-- .,,,,,,-,.w,,--e ,r,,,----,,+,-~m -+,.,, - -,+ ~-,,~wy-~, m-
ew o r. *,. 1, ( -{ eestu.t ne o e-r~"h u J."*d-r* c..se n.,e,,ernt, . n niegn ' fest Reseits, net <isiss %.1/s, self foriy,,j -reeti.3 frope n 'teod/< ~d CER0t10 LOGY REGARDING PLANT Fill.' DEFICIENCIES fl*.t-paitsle,./ Z# D*TE j A<teJ Nortebr>6,8111. l . 03/22/82 Staff letter compiling information requested for completion \\ of staff review of Phase 2 Jinderpinning for Auxiliary A Building 4 i 03/2f/82 Staff letter of concurrence to grout c' racks in the existing concrete foundations of the BWSTs 4 n:.. ..m
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