Anti-freezing layer does not used in case of non frost heaving in subgrade soils. In this case, the modulus of subgrade soils were varied with freezing and thaw cycles under non frost heaving. That effect should be properly considered in pavement design. Impact resonance test that is nondestructive testing method was used for continuously determining the modulus of subgrade soils during freezing and thaw cycle. The modulus of subgrade soils was identical with freezing and thaw cycles under closed freezing and thaw system which is no water supplement into specimen during testing. There was also no difference in the modulus of subgrade soil between before and after freezing-thaw cycles for all specimens with different water content and density. That is thaw-weakening of subgrade soils do not occur under closed freezing and thaw system. The moduli at freezing conditions are varied with water content and density, but it can be ignored in practical design sense.