ML19338D045
| ML19338D045 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/16/1980 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19338D046 | List: |
| References | |
| 9584, NUDOCS 8009190218 | |
| Download: ML19338D045 (3) | |
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James W Cook
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l fl Voce 14e sident, Ats.fl.and l>aject General o t hces: 1945 West Parnali Road. Jackson, Michigan 49201 *(517) 788-o640 September 16, 1980 Mr Richard H Vollmer, Director Division of Engineering US Nuclear Regulatory Commission Phillips Building 7920 Norfolk Avenue Bethesda, MD 20014 MIDLAND PROJECT DISCUSSION OF THE APPLICANT'S POSITION ON THE NEED FOR ADDITIONAL B0 RINGS FILE: 0485.16 UFI:
71*01, 00234S SERIAL:
9584 On August 29, 1980, Consumers Powar and its Consultants made presentations to you and your associates, Messrs Kr.ight and Lear, on the adequacy of the remedial actions either underway or planned for those Midland Nuclear Plant structures found on improperly compacted fill. This meeting was called specifically to request relief.from the NRC Staff's posit. ion that additional borings and tests were necessary in order for the Staff to complete their review in this matter. At the conclusion of that meeting we agreed to document our presentations at the same time we submitted additional data describing the ongoing site soils work. That submittal was made on September 15,'1980 as Anendment 81 to the Midland SAR.
At the appeals meeting I was asked why Consumers Power had requested the mee ting. My response was that the Company's purpose was to utilize this process, hopefully, as a means to resolve the open questions and bring the review to a timely completion which would include agreement with the Staff on the adequacy of the remedial soils program.
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l This letter transmits for your consideration the portion of the amendment entitled, " Discussion of the Applicant's Position on'the Need for Additional Borings." This self-contained discussion attempts both to document the presentations and new material introduced at the August 29th meeting and to l
summarize.in one place, the data and the issues discussed with the Staff at q
several meetings and through a number of submittals.
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In preparing the attached report I hope that we have been able to adequately communicate the rationale and data supporting our position. To date I do not believe we have been entirely successful in this task because of a number of difficult circumstances. These include the length of the review (currently approaching two years), the introduction of new information, individuals and organizations into the process at varf ng times, and the voluminous amount of i
data and analyses that have been submitted.
As you evaluate the flidland soils issues, I urge you to consider the following points which I believe speak to the heart of the question.
o The remedial program undertaken by Consumers is essentially based on direct measurements and proof testing, all of which are verifiable.
In matters of public health and safety, it is the exception rather than the rule that enables a question to be resolved in this fashion rather than purely by analysis.
o Independent verification of the adequacy of our program appears to be the sole rationale given by the Staff to justify their regi est for additional borings and lab tests.
It is my understanding that independent verification is not restricted to analyzing the problem by a completely dif ferent analytical method.
This is paricularly t' rue if the alternate methodology is demonstrably inferior and has the potential for confusing, not clarifying the question.
A better means of independent verification in this instance would seem to be reproducing with the best methods the settlement predictions and other key parameters using basic data that can be checked or directly measured by the Staff.
This process could include witnessing the pile and caisson proof tests and then using the appropriate test data in reviewing the final design of the underpinnings.
o No matter what the predictive work indicates, the ultimate verification mechanism will be direct measurement of the actual settlement of all Category I structures and the groundwater level over the plant lifetime.
This procedure will be a technical specification requirement even if no problem had been observed.
It will provide ample warning of any further excessive settlement although a year's data provides compelling evidence that this problem has been corrected in the only place it has occurred.
This mechanism is a direct and positive assurance of public safety.
o With regard to questions concerning the coolir.g pond dike, we remain.
confused over the introduction of this nonsafety related strucLure into the NRC's review.
It would appear that these questions are outside the scope of the current soils hearing.
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3 I hope this submittal will assist you and your colleagues in evaluating the While it is my understanding that we have open questions in this matter.
that conciusion must be addressed every Staff concern of which we are aware, As a result, we stand ready to provide you and/or the verified by the Staff.
Staff any further information or clarification needed with regard to our soils In addition, since our purpose is not so much to avoid additional activities.
is to find a way to assure the NRC of the adequacy of our soils borings as it program, I offer my services to you and your colleagues to do whatever I can to expedite the resolution of these questions.
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/GELear, NRC (w/a)
OM IIcaring Service List (w/o) e r
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